Document of The World Bank FOR OFFICIAL USE ONLY Report No. 54427 - DJ PROJECT PAPER ON A PROPOSED ADDITIONAL GRANT IN THE AMOUNT OF SDR 2.0 MILLION IN PILOT CRW RESOURCES (US$2.9 MILLION EQUIVALENT) TO THE REPUBLIC OF DJIBOUTI FOR THE URBAN POVERTY REDUCTION PROJECT May 19, 2010 Sustainable Development Middle East and North Africa Region This document has a restricted distribution and may be used by recipients only in the performance of their official duties. Its contents may not otherwise be disclosed without World Bank authorization. DJIBOUTI URBAN POVERTY REDUCTION PROJECT CURRENCY EQUIVALENTS Currency Unit = DJF (Djiboutian Franc) US$1.00 = DJF 175.75 Exchange Rate Fixed Under Currency Board Arrangement WEIGHTS AND MEASURES Metric System FISCAL YEAR January 1 - December 31 ABBREVIATIONS AND ACRONYMS ADDS Djibouti Social Development Agency (Agence Djiboutienne de Développement Social) ADETIP Djibouti Public Works Agency AF Additional Financing AFD French Development Agency AfDB African Development Bank CAS Country Assistance Strategy CDC Community Development Center CRW Crisis Response Window DUPREP Djibouti Urban Poverty Reduction Project FSN National Social Fund IDA International Development Association INDS National Initiative for Social Development IsDB Islamic Development Bank ONEAD National Water and Sanitation Authority PDO Project Development Objectives PPIAF Public-Private Infrastructure Advisory Facility Q7 Quartier 7 (area of intervention) SDR Special Drawing Rights TA Technical Assistance UNICEF United Nations Children's Fund Vice President: Shamshad Akhtar Country Director: A.David Craig Sector Director/Manager: Laszlo Lovei/ Anna Bjerde Task Team Leader: Alexandra Ortiz 2 DJIBOUTI URBAN POVERTY REDUCTION PROJECT TABLE OF CONTENTS Memorandum of the President 4 Project paper data sheet 5 I. Introduction 6 II. Background and Rationale for Additional Financing 6 III. Proposed Changes 11 IV. Appraisal Summary 13 Annex 1: Revised Results Framework and Monitoring Indicators 17 Annex 2: Operational Risk Assessment Framework 23 Annex 3: Detailed Description of Modified or New Project Activities 29 Annex 4: Revised Estimate of Project Costs 31 Annex 5: Safeguard Policy Issues 33 3 MEMORANDUM AND RECOMMENDATION OF THE PRESIDENT OF THE INTERNATIONAL DEVELOPMENT ASSOCIATION TO THE EXECUTIVE DIRECTORS ON A PROPOSED ADDITIONAL GRANT TO DJIBOUTI FOR THE DJIBOUTI URBAN POVERTY REDUCTION PROJECT IDA H582-DJ 1. I submit for your approval a proposed additional grant to the Republic of Djibouti in the amount of SDR 2.0 million for the Djibouti Urban Poverty Reduction Project (IDA H582-DJ). The additional grant would be an IDA Grant using pilot CRW resources. 2. The proposed additional grant would finance additional economic and social community development activities within Quartier 7, the largest and one of the poorest neighborhoods in the city of Djibouti. It will support the executing agency, the Djibouti Social Development Agency (ADDS) to implement additional and expanded activities to scale up the project's impact and development effectiveness and will enhance the results of a well-performing project. There will be neither changes in the PDO nor in the project components. 3. Recommendation. I am satisfied that the proposed grant would comply with the Articles of Agreement of the Association and recommend that the Executive Directors approve it. Robert B. Zoellick President Washington, DC May 19, 2010 Vice President: Shamshad Akhtar Country Director: A.David Craig Sector Director/Manager: Laszlo Lovei/ Anna Bjerde Task Team Leader: Alexandra Ortiz 4 PROJECT PAPER DATA SHEET Date: May 19, 2010 Team Leader: Alexandra Ortiz Country: Djibouti Sector Director: Laszlo Lovei Project Name: Djibouti Urban Poverty Sector Manager: Anna Bjerde Reduction Project Country Director: A. David Craig Original Project ID: P088876 Environmental Category: B AF Project ID: P120190 ORAF Rating: Moderate Borrower: Republic of Djibouti Responsible agency: ADDS (Agence Djiboutienne de Développement Social) Revised estimated disbursements (Bank FY/US$m) (Original Project + AF) FY 09 10 11 12 13 Annual 0.5 0.8 1.7 2.0 0.9 Cumulative 0.5 1.3 3.0 5.0 5.9 Current closing date: May 31, 2012 (as per standing Financing Agreement) Revised closing date: May 31, 2013 (as per proposed Grant) Does the restructured or scaled-up project require any exceptions from Bank policies? Yes No Have these been approved by Bank management? Yes No Is approval for any policy exception sought from the Board? Yes No Does the scaled-up or restructured project trigger any new safeguard policies? Yes. The environmental category was upgraded from C to B For Additional Financing [ ] Loan [ ] Credit [X] Grant For Loans/Credits/Grants: Total Bank financing (US$m.): 2.9 Proposed terms Financing Plan (US$m.) (AF) Source Total Borrower IBRD/IDA 2.9 Others Total 2.9 Financing Plan (US$m.) (Original project + AF) Source Total Borrower 7.0 IBRD/IDA 5.9 African Development Bank 12.0 Islamic Development Bank 8.5 Agence Francaise de Développement 8.0 Others Total 41.4 Note: Some minor changes could have taken place regarding the contributions of other donors 5 I. Introduction 1. This Project Paper seeks the approval of the Executive Directors to provide an additional grant of SDR 2.0 million (US$2.9 million equivalent) to the Republic of Djibouti for the Djibouti Urban Poverty Reduction Project (original project ID number: P088876; original credit number: IDA H356-DJ). This financing would come under the IDA Crisis Response Window. 2. The proposed additional grant would support the executing agency, the Djibouti Social Development Agency (ADDS), to implement additional and expanded activities to scale up the project's impact and development effectiveness whereby enhancing the results of a well performing project. There will be neither changes in the PDO nor in the project components. The AF will be used to finance additional economic and social community development activities within Quartier 7. 3. These activities will help beneficiaries cope with difficult living conditions, which have worsened with the global economic crisis, by providing better access to urban services, to jobs, to recreation opportunities, and to community development. II. Background and Rationale for Additional Financing in the amount of US$2.9m 4. Djibouti is a small, resource-poor country of 23,200 square kilometers, located in the Horn of Africa at the southern end of the Red Sea. It is poorly endowed with natural resources and has limited arable land, rainfall, and underground water. The country's population is estimated at 818,159 people, 71 percent of which live in urban areas (Djibouti Census, 2009). Djibouti is essentially a city-state with about three fifths of dwellers living in the capital city. The hinterland, an extension of the deserts of Ethiopia and Somalia, is sparsely occupied by a poor pastoral and nomadic population. 5. Djibouti's economy is based on service activities connected with the country's strategic location and status as a free trade zone in northeast Africa. Djibouti provides services as both a transit port for the region and an international transshipment and refueling center. It also hosts two large military bases. In 2008 Djibouti's real GDP grew by 5.9 percent, driven mainly by foreign direct investments (FDI) in construction and maritime services. According to the World Bank, Djibouti's strong externally financed public investment and the growing diversification of maritime services will allow Djibouti to decrease its dependence on Ethiopian trade and will support a sustained real GDP growth. 6. Poverty in Djibouti-ville is considered to be very high at 69.3% according to national statistics (EDAM-IS2, 2002). It translates in very low access to basic services, the prevalence of informal housing, poor health indicators, low levels of educational attainment, high rates of illiteracy, and high levels of unemployment. The Djibouti Urban Poverty Reduction Project was designed to address poverty issues in Quartier 7, the largest and one of the poorest neighborhoods in the city. Along with projects financed by the African Development Bank (AfDB), the Islamic Development Bank (IsDB), and the 6 French Development Agency (AFD)1, the IDA financed urban sector operation is one of the constituents of the country's urban poverty reduction program. 7. An IDA grant of US$3 million to support the Djibouti Urban Poverty Reduction Project (DUPREP), was approved on April 29, 2008, and became effective on January 29, 2009. 8. The project development objective is to increase access to basic economic and social infrastructure and to community development opportunities within Quartier 7 in the city of Djibouti. The project has three components as follows: (i) improvement of infrastructure; (ii) community development; and (iii) technical assistance. 9. The first component, (i) Improvement of Infrastructure, includes the rehabilitation of key internal roads and their corresponding drainage systems, the construction of a community center, the upgrading of an abandoned public garden, and the construction of sports and recreation centers. The second component, (ii) Community Development, includes the financing of environmental management activities at the community level (in the areas of sanitation and solid waste collection), literacy campaigns, vocational training, and strengthening the capacity of neighborhood associations. The third component, (iii) Technical Assistance, includes training and development of management and technical tools for the implementing agency, as well as the financing of a project coordinator and implementation fees. An unallocated amount has been reserved to provide flexibility during project implementation. 10. The executing agency, The Djibouti Social Development Agency (ADDS), which was created officially in January 2008 after the merger of the Djibouti Public Works Agency (ADETIP) and the National Social Fund (FSN), is fully operational. The agency has developed its organizational chart and detailed job description, as well as all its operational manuals. The agency is now fully staffed. 11. The project performance is fully satisfactory and translates into a disbursement rate of 27 percent fifteen months after declaration of effectiveness. Details on the progress under each component are summarized below. 12. Component 1: Improvement of Infrastructure. Construction of the community center has started and advancement is estimated at 90 percent. Preliminary designs for the roads, drainage, public garden and recreation centers have been completed and have been revised and validated by the Bank team. The corresponding bidding documents have been completed and are under review. 13. Component 2: Community Development. There has been significant progress in the execution of this component. The sanitation sub-component has been aligned with the recently approved overall Djibouti Sanitation Plan and aims to improve sanitation 1 The projects financed by the IsDB and AFD cover neighborhoods in Balbala, in the outskirts of Djibouti- ville while the project financed by the AfDB covers neighborhoods in five secondary centers. 7 conditions through awareness and support for individual latrine upgrading2. The activities developed so far include: training of ADDS staff in Burkina Faso at a strategic level, training of ADDS staff in Djibouti at technical and social levels, replication of the latter training to the neighborhood associations, and training to households, which is currently ongoing. Other activities that will be developed this year include the setting-up of a show room, training of latrine manufacturers, and financing of latrine upgrading and/or acquisition through an ADDS micro-financing window. 14. The public hygiene sub-component has been launched in October 2009, through a specialized technical assistance financed by PPIAF. The objective of the TA is to identify a suitable and replicable model for solid waste collection within the neighborhood using local micro-enterprises. 15. Literacy campaigns started in October 2009 and a demand-driven vocational training program is underway. The strengthening of community associations is also under implementation. A significant effort of project information and dissemination has been made. ADDS is also considering placing one or two of its social development experts in the field in order to achieve a better follow-up with neighborhood residents and elected officials. 16. Component 3: Technical Assistance. The Bank recently awarded the no-objection for the updating and extension of ADDS's information and management system. Several training activities for ADDS staff have also been financed under this component. 17. Cooperation among international donors has been very good. The Bank team is coordinating all its activities with the African Development Bank (AfDB), the French Development Agency (AFD), and the Islamic Development Bank (IsDB). In particular, the strengthening of ADDS has been the subject of collaboration and synergy. 18. Cooperation with other agencies, in order to have a larger impact, has been excellent. This has been particularly the case for the National Water and Sanitation Authority (ONEAD), the Djibouti Solid Waste Department, the National Association of Djiboutian Women, the City Planning Department, and UNICEF. 19. In spite of all the efforts made, much remains to be done in Quartier 7. Quartier 7 is the largest neighborhood in the city, with 23,000 inhabitants out of Djibouti city's 475,322, and one of the poorest: the proportion of residents living below the poverty line is over 65 percent, with one full third of the work-force unemployed. The neighborhood is in need of much improvement beyond what is included in the project. Neighborhood residents, who have successfully been mobilized under the project, have expressed the urgent need to: (i) rehabilitate at least two other main roads; (ii) improve the drainage in the neighborhood in addition to the main axes already covered by the project, an action that would mitigate the current high risk of house flooding; (iii) construct additional sports and recreation centers as youngsters are the most vulnerable population in the neighborhood; (iv) construct the health center that had originally been envisaged during 2 Those activities have been prepared with the National Water and Sanitation Authority (ONEAD), and with support from UNICEF. 8 DUPREP preparation but dropped due to the very limited funds available; and (vi) supply green spaces to improve air quality and environmental prospects. Regarding social development, the neighbors, local authorities, and ADDS social team, agree that more funds are needed to complement the existing activities and increase the number of beneficiaries. On the other hand, Djibouti-ville lacks a comprehensive urban development strategy in order to better coordinate the contribution made by donors, as well as provide the city with a short, medium and long term action plans to enhance (i) the productive capacity of the city, (ii) social cohesion, and (iii) the sustainability of investments. 20. Taking into account the above described needs the additional financing, estimated at SDR 2.0 million (approximately US$2.9 million) will help implement additional and expanded activities to scale up the project's impact and development effectiveness (OP/BP 13.20). 21. Consistency with Country Assistance Strategy (CAS): The Djibouti Urban Poverty Reduction Project is part of the CAS-supported operations that are aligned with the National Initiative for Social Development (INDS). Theme 2 of the CAS, approved by the Board on April 29, 2009 focuses on supporting access to basic social services and human development through (i) improved access to quality basic education, (ii) improved access to and quality of health services, and (iii) strengthened social protection and direct support to the poor. The current project supports this CAS theme, by financing basic economic and social infrastructure to increase community development opportunities in poor areas of Djibouti. 22. Financing under IDA's crisis window is justified by the following elements: - The global financial crisis has impacted IDA-eligible countries across the world which were already coping with the impact of food and oil prices rise, prompting a strong response from the international community. The Crisis Response Window was established within the IDA financial architecture to assist IDA countries in dealing with the current global crisis, and protect core spending on health, education, safety nets, infrastructure and agriculture. - After a period of growth acceleration (growth doubled between 2004 and 2008), Djibouti's real GDP growth slowed down to about 5.0 percent in 2009. In Djibouti, growth is driven by large foreign private investments in ports services and the construction sector. The deceleration in growth is attributed to the cancellation or postponement of a few important FDI projects in 2008 after the onset of the global economic crisis. Consequently, FDI fell from 23.8 percent of GDP to estimated 18.0 percent of GDP in 2009 and are projected to decline to 15.7 percent of GDP in 2010 (Djibouti Economic Update, Spring 2010). - But more than the financial crisis, it has been the energy crisis and the food security situation that hve affected Djibouti. After recovering from the price shock of 2008, the food security situation is once again worsening. Rainfall has been low in the last season and has led to a high level of livestock mortality. This and the limited access to drinking water are jeopardizing the livelihoods of pastoral farmers who belong to the poorest and most vulnerable segment of society. The situation is 9 compounded by the influx of additional refugees. Approximately 5,000 more refugees from Somalia are expected, in addition to the 12,000 existing refugees that continuously require food assistance. - Migration to Djibouti's capital city has been a byproduct of the food crisis and has exacerbated the precarious situation in the poorest neighborhoods. High unemployment persists: an estimated 40 percent of the labor force is unemployed. The Government is addressing unemployment with vocational training initiatives and the promotion of self-employment through micro-credit schemes, many of which are managed by ADDS. - The precarious natural situation of Djibouti is compounded by its vulnerability to natural disasters, including severe droughts that add to the aridity of the weather and result in very little arable land, periodic floods with a recurrence period of 10 years, earthquakes which are usually between 2 and 4 in the Richter scale but that could have important effects in the built environment, notably where there has been urbanization on inadequate soils, and fires fueled by the use of inadequate construction materials such as cardboard, plastic, and leaves. - DUPREP's focus on provision and improvement of basic infrastructure in one of the capital city's poorest and largest neighborhoods, is crucial to prevent natural disasters (the case of drainage), to prevent water borne diseases (the case of sanitation and solid waste management), to provide better access to city jobs (the case of roads), to offer alternatives for community education and recreation (community and recreation centers), and to provide much needed open and green space (public garden). - The Government's approach to building infrastructure favors, wherever possible, the use of intensive labor, which helps create employment within the neighborhood. Although this employment is by nature temporary it has the potential to generate know-how and to boost overall confidence in beneficiaries. - The project's social component is very much geared towards supporting the community with key activities that can have a multiplier effect, such as literacy campaigns, demand-driven vocational training, and strengthening of community associations, all of which are crucial during times of crisis. - The project has leveraged many additional resources (PPIAF, Water and Sanitation Program, UNICEF) in part because of its integrated infrastructure and social development approach, and in part because of ADDS's solid track record. - Although the project works only in one neighborhood in Djibouti-ville, its approach seeks to make its benefits extensive to other neighborhoods (sanitation plan, solid waste collection model). In addition, the projects financed by AfDB, AFD, and IsDB are all complementary and reach other neighborhoods in the city (AFD and IsDB) and smaller cities of the interior (AfDB). 10 III. Proposed Changes 23. The project's development objective would remain unchanged. 24. The proposed additional activities would fall into the existing components as follows (detailed description and estimated cost of these activities are included in Annex 3): - Component 1, Improvement of Infrastructure: rehabilitation of 1.5 km of streets, including street lighting, drainage works in priority areas, construction of a health center, and supply of public and green spaces; - Component 2, Community Development: additional funds for activities in favor of local environment quality (sanitation and solid waste), vocational training literacy campaigns, activities to support women and youth communities, and social awareness and mobilization; - Component 3, Technical Assistance: (i) preparation of technical studies and bidding documents for civil works; (ii) supervision of works; (iii) project implementation in general; (iv) provision of training for ADDS staff; (v) preparation of urban development studies to support the preparation of a Master Plan for the Greater Djibouti Ville Area; and (vi) support to the project implementing agency. 25. The environmental safeguard category is upgraded from C to B to be in line with the most current definitions of these categories (please refer to paragraphs 38-41 for more information). 26. Project outcome indicators: The work to be carried out with the additional financing would enable the project to fully meet its development objectives. To reflect the changes described above, the original results framework was adjusted as follows: modification of 2 original outcome indicators, addition of two new outcome indicators, upward revision of four outcome indicator's target value, and change of selected intermediary indicators. Monitoring and evaluation arrangements will remain unchanged: the outcomes and results of the project will be carried out by an ADDS department fully dedicated to project monitoring and evaluation. 27. The revised project outcome indicators framework is: Table 1. Project Outcome Indicators Project Outcome Indicators Original Target Changes with AF* Revised Target* Indicators Basic infrastructure # % of households willing to 10% 0 10% invest in new Latrines Basic infrastructure # 70% 0 70% 11 % of households benefiting from an organized solid waste collection Basic infrastructure Number of properties within 50 35% increase 15% increase 50% increase m from surfaced roads. Basic infrastructure* Reduction of rain water 20% 20% 40% evacuation time Facilities Number of Q7 residents using 1000 0 1000 the Community Development Center and its equipments. Facilities* % of Q7 residents frequenting 0 70% 70% the Health Center. Community Development Percentage residents of all age groups benefiting from 10% 0 10% community development sub- projects Job creation Number of person-days of short 8000 4000 12000 term employment created through project * New AF indicators # Modified Indicators 28. Costs by component:(detailed revised estimate of project costs in Annex 4) Table 2. Costs by Component PROJECT COMPONENTS Original COST Cost with Changes Revised Cost (in US$) REALLOCATION with AF (in US$) (in US$) (in US$) 1,600,000 1,452,000 COMPONENT 1: IMPROVEMENT OF 1,620,000 3,072,000 INFRASTRUCTURE COMPONENT 2: COMMUNITY 350,000 195,000 693,000 DEVELOPMENT 498,000 COMPONENT 3: TECHNICAL ASSISTANCE (including engineering designs and supervision, 426,000 426,000 679,000 1,105,000 urban planning studies) ADDS fees 180,000 180,000 168,000 348,000 TOTAL BASELINE COSTS 2,556,000 2,556,000 2,662,000 5,218,000 UNALLOCATED 444,000 444,000 238,000 682,000 TOTAL FINANCING REQUIRED 3,000,000 3,000,000 2,900,000 5,900,000 12 IV. Appraisal Summary 29. Economic and financial analyses: The proposed additional financing will cover the scaling up of existing activities and some additional activities which are, in nature, similar to the ones included in the project. 30. The economic analysis of the project was carried out using a hedonic price methodology which allows calculation of the marginal contribution of each type of investment (roads, drainage, lighting, etc) to the estimated increase in property values. The study was based on a household survey of 153 households in Quartier 7 and 46 in the comparison neighborhood, PK12. The estimation of monthly rents by property residents was used as a proxy for property values. 31. The following variables were included in the analysis: (i) internal characteristics of the property such as construction material, floor type, roof material, area, number of rooms, existence of property title; (ii) characteristics related to the infrastructure such as type of water service, type of sanitation service, road surface, quality of drainage, existence of sidewalk, existence of lighting, distance to community and recreation centers; and (iii) within city location. 32. The estimated Economic Rate of Return (ERR) was of 12%. The study shows that the package of infrastructure investments has a positive and significant impact in the increase of property values even if individually some of these investments might not have such a significant effect. Since the additional finance will include similar investments to those of the project and that these were included in the original economic study, there is no need to carry out a new economic study. 33. Technical. The infrastructure works included in the additional finance, as well as those included in the project, have been selected after considering the needs and priorities expressed by the community, as well as the neighborhood development plan prepared by the City Planning Department, in consultation of technical aspects with ONEAD, the Solid Waste Department, and the Ministry of Health, and taking into account costing and overall technical feasibility. 34. Fiduciary. Regarding the fiduciary aspects of the project, the procurement rating is satisfactory, given that a procurement unit was established in early 2009 and it is performing well. This unit, as well as a part of the directive personnel of ADDS, have been the object of procurement training. Nevertheless the procurement risk has been identified as substantial and it is expected to be reduced to moderate with the mitigation action proposed in the risk matrix. 35. Procurement under the project will be carried out in accordance with the "Guidelines on Preventing and Combating Fraud and Corruption in projects Financed by IBRD Loans and IDA Credits and Grants" known as the "2006 Anti-Corruption Guidelines" and the "Guidelines: procurement under IBRD Loans and IDA credits" published by the Bank in May 2004 and revised in October 2006 and the "Guidelines: 13 Selection and Employment of Consultants by World Bank Borrowers" dated May 2004 and revised October 2006, and the accompanying standard bidding documents for any new procurement. 36. Financial management has also been rated satisfactory. At this stage ADDS launched the process to designate the auditor for the project. The first audit report is due in June 2010. The current disbursement arrangement, which is working satisfactorily, remains appropriate for the Project and will not be changed. The same arrangements for the Designated Account and SOEs will be used. 37. Social. The social component of the project is satisfactory. All the activities have been launched and mobilization of residents in the neighborhood is substantial. The additional finance will build on these positive outcomes. In addition, ADDS completed in early 2009 a study of the social conditions in the neighborhood which allowed the construction of a detailed household profile and the identification of the most pressing needs. The study combined two methodologies: a household survey (153 households) and focus groups with special groups (women, men, young women, young men). 38. Environment: Project interventions would cause significant environmental improvements to the area and limited potential negative impacts are envisaged. All projected interventions in the Quartier 7 would contribute significantly to its environment, starting with the installation and rehabilitation of drainage canals along some streets, and including improved access to sanitation systems. The introduction of a community garbage collection system, would also contribute to an improved environment. The upgrading of the neighborhood public garden would increase the green coverage and create a much needed environmental amenity for the residents. Finally, the additional finance will also include landscaping of the community center and recreation spaces in order to make the neighborhood a greener space and increase the awareness of residents regarding the importance of the environment. 39. In terms of the environmental safeguard the proposed additional finance will be category B since its potential adverse environmental impacts on human populations and environment are site specific and none of them are irreversible. The infrastructure works to be included in Component 1 are of very limited scale: 1.5 Kms of road rehabilitation, cleaning of 2.3 Km of drains, and construction of a 750 m2 health center. Minor negative effects are limited to noise and dust during construction, as well as difficulties to walk by the sites because of the presence of machinery. These impacts will be controlled with appropriate signs and specific hours of machinery operation to decrease the nuisance. 40. The proposed health center will produce a very limited amount of medical waste because it is a preventive center dealing only with prenatal checkups, vaccinations, assistance to deal with and prevent malnutrition, and general outpatient consultation. The medical waste will be eliminated using a small incinerator, according to Djibouti's Ministry of Health guidelines to handle medical waste. The municipal solid waste stream to be collected under Component 2 has been evaluated at 190 m3 per week and will be directed to the city's waste disposal center in Doudah, 20 km southeast of the city. There 14 is no sanitary landfill in Djibouti but the government has started discussions with the European Commission to finance one in the future. 41. ADDS has a proven capacity to carry out environmental analyses, capacity that has been acquired after working in several IDA-financed projects (Social Development and Public Works Project, 1999-2007, including additional finance, Flood Emergency Rehabilitation Project, 2004-2009, including additional finance). ADDS has an environmental manual that was developed using World Bank environmental guidelines and the experience of public works agencies in Africa (AGETIPs). The manual was recently updated and includes procedures for approval of environmental impact studies in Djibouti, methodology to carry out such studies, categorization of projects, and templates for simplified environmental review, impact mitigation plan, conditions for implementation, and TORs for consultants. 42. The specific environmental study for the current project has been reviewed by the team's environmental specialist and cleared by the Safeguards team. The study along with the manual have been made available to the public in ADDS's headquarters and its internet web site (www.adds.com) and in the Bank's Infoshop (April 23, 2010). It is envisaged that additional training will be provided to ADDS staff in the area of environmental management in order to reinforce its knowledge and instruments. 43. The project is not expected to entail any involuntary resettlement. Given the nature and layout of the Quartier 7, with all the individual properties aligned on the street-fronts, the rehabilitation of the drainage network would be carried out on the public right of way. The construction of the Health Center, and the multipurpose playground would be taking place on public land. As for the community development component, none of the activities foreseen would entail any relocation or resettlement either. Table 3. Safeguard Policies Safeguard Policies Triggered by the Project Yes No Environmental Assessment (OP/BP 4.01) [x] [ ] Natural Habitats (OP/BP 4.04) [] [ x] Pest Management (OP 4.09) [] [ x] Physical Cultural Resources (OP/BP 4.11) [] [ x] Involuntary Resettlement (OP/BP 4.12) [] [ x] Indigenous Peoples (OP/BP 4.10) [] [ x] Forests (OP/BP 4.36) [] [ x] Safety of Dams (OP/BP 4.37) [] [ x] Projects in Disputed Areas (OP/BP 7.60)3 [] [ x] Projects on International Waterways (OP/BP 7.50) [] [ x] 3 By supporting the proposed project, the Bank does not intend to prejudice the final determination of the parties' claim on the disputed areas 15 44. No exceptions are requested to the Bank's policies and the project readiness is considered sufficient for approval of the proposed operation by the Board of Directors. 16 Annex 1: Revised Results Framework and Monitoring PDO Project Outcome Indicators Use of Project Outcome Information Current Proposed Current Proposed* Current Proposed Basic infrastructure Basic infrastructure Basic infrastructure Basic infrastructure Target: Target: The basic The basic (i) 35% increase of (i) 50% increase of infrastructure indicator infrastructure indicator properties within 50 m properties within 50 m will measure the will measure the from surfaced roads. from surfaced roads. increased and increased and improved access to improved access to (ii) 10% of households (ii) 10% of households basic infrastructure, basic infrastructure, willing to invest in new willing to invest in new sanitation and public sanitation and public Latrines. Latrines. spaces spaces The project development objective (iii) 70% of households (iii) 70% of households (PDO) is to increase benefiting from an benefiting from an access to basic organized solid waste organized solid waste economic and social collection. collection. infrastructure and to No Change community (iv) 40% reduction of rain development water evacuation time opportunities within Facilities Facilities Facilities Facilities Quartier 7 in the city The facilities indicator The facilities indicator of Djibouti Target: Target: will measure the level will measure the level 1000 Quartier 7 residents (i) 1000 Quartier 7 of access to the of access to the making use of the residents making use of the Community Community Community Development Community Development Development Center Development Center Center and its equipments. Center and its equipments. built and equipped built and equipped under the project under the project and (ii) 70% of Quartier 7 the Health Center Built residents making use of under the project. health center. Community Development Community Development Community Community 17 Development Development Target: Target: The community The community 10% of Quartier 7 10% of Quartier 7 development indicator development indicator residents of all age groups, residents of all age groups, will measure the will measure the of which 50% women, of which 50% women, percentage of the percentage of the benefit from the benefit from the resident population resident population community development community development having directly having directly sub-projects. sub-projects. benefited from the benefited from the community community development sub- development sub- projects projects Job creation Job creation Job creation The job creation The job creation indicator will measure Target: Target: indicator will measure the number of person- 8,000 person-days of short 12,000 person-days of the number of person- days of short-term term employment created short term employment days of short-term employment generated under the project. created under the project. employment generated under the project under the project investments investments Intermediate Outcomes Intermediate Outcome Indicators Use of Intermediate Outcome Indicators Current Proposed Current Proposed* Current Proposed Basic infrastructure Basic infrastructure 25% 25% This monitoring will This monitoring will Completion of road Completion of road keep track of the keep track of the rehabilitation and rehabilitation and largest infrastructure largest infrastructure drainage works drainage works investment investment Facilities Facilities 100% 100% This monitoring will This monitoring will Construction of various Construction of keep track of the keep track of the community facilities community construction of the construction of the development center essential new facility under construction and Facilities 0% 0% new facilities Construction of Health center Facilities 0% 0% Construction of playgrounds commercial spaces 18 Community Community 2 components launched 4 components launched This monitoring will This monitoring will Development Development and the rest identified and the rest identified keep track of keep track of Completion of Completion of community community community community involvement and involvement and development sub- development sub- mobilization mobilization projects projects 19 Arrangements for results monitoring Baselines Target Values Data Collection and Reporting Project Outcome Indicators Original At AF YR1* YR2* YR3* Frequency Data Responsibility appraisal and Collection for Data Reports Instruments Collection Current Proposed Basic Basic infrastructure Quarterly Contract ADDS infrastructure reports documentation (i) % increase of (i) % increase of 0 15% 30% 50% properties properties within 50 0 within 50 m m from surfaced from surfaced roads. roads. ii) % of 0 2% 5% 10% ii) % of households willing 0 households to invest in new willing to invest latrines. in new latrines. 0 10% 50% 70% (iii) % of (iii) % of 0 households households benefiting from benefiting from an an organized organized solid solid waste waste collection. collection. 0 0 10% 20% 40% (iv) % reduction of rain water evacuation time Facilities Facilities Quarterly Documentation ADDS reports of social (i) # of Quartier (i) # of Quartier 7 0 0 1000 1000 1000 department 7 residents residents making (inscriptions) making use of use of the 20 the Community Community Development Development Center and its Center and its equipments. equipments. 0 0 70% 70% (ii) % of Quartier 7 residents making use of health center Community Community Quarterly Memorandums ADDS Develop. Develop. reports of understanding % of Quartier 7 % of Quartier 7 with residents of all residents of all age associations age groups, of groups, of which 0 2% 5% 10% 10% which 50% 50% women, women, benefit benefit from the from the community community development sub- development projects. sub-projects. Job-creation Job-creation Quarterly Contractor ADDS reports reports person-days of person-days of short short term term employment 0 3,000 5,000 8,000 12,000 employment created under the created under project.c the project. Intermediate Outcome Indicators Mid-term Mid-term evaluation World Bank Current Proposed report Basic Basic 0 0% 80% Contract infrastructure infrastructure Preliminary documentation Completion of Completion of road Design road rehabilitation and Complete rehabilitation drainage works and drainage 21 works Facilities Facilities 0 80% 100% Contract Construction of Construction of documentation various community community development center facilities Facilities* 0 0 80% Contract Construction of documentation Health center Community 0 10% 4 components Memorandums Development launched and of Completion of Literacy the rest understanding community program identified with development launched, associations sub-projects sanitation training underway, assessment studies for the professional training and for the strengthening of community associations complete, PPIAF solid waste TA launched. * New AF component 22 Annex 2: Operational Risk Assessment Framework Risk factors Description of risk Ratinga of Mitigation measures Ratinga of risk residual risk I. Country- and or Sub-National Level Risks Macroeconomic Over the last few years, Djibouti experienced large FDIs and Substantial The Bank is keeping a steady Moderate framework high growth. However, there is the possibility that the recent dialogue with the Government global crisis could have a negative impact on the country's and is, jointly with the IMF, economic activities through delayed FDIs and reduced monitoring Djibouti's volume of trade passing through Djibouti's ports. economic situation. The Bank is also aiming to respond Djibouti's balance of payment is affected by structural trade rapidly to crises as they arise in deficit due to weak domestic production base. The country is Djibouti (e.g., food crisis DPO extremely vulnerable to price shocks (e.g., food, fuel). It in May 2008). depends on imports for more than 90 percent of its needs in food products and 100 percent for fuel. Sector policies and The Country Policy and Institutional Assessment (CPIA) Moderate The Bank will continue to Moderate institutions overall rating of 3.1 for Djibouti has remained the same for encourage the Government to the last three years (2006, 2007, 2008). This low CPIA rating improve the CPIA rating affects IDA allocation to Djibouti. (taking advantage of the Country Governance and Anti- The business environment is mixed, with a highly favorable Corruption work to determine regime in the free zone, and a more restrictive set of priority areas for governance regulations in the rest of the country (although in view of the reform). size of Djibouti, most enterprises can establish themselves in the free zone). The Bank team will work closely with the Government Civil service remains an issue with regard to capacity and in strengthening its capacity to delivery. Public institutions are typically weak across the address issues that affect the board. However, the creation of the Agence Djiboutienne de public sector management and Développement Social was a positive step to strengthen institution and the overall delivery of public infrastructure, especially for social institutional weakness. development. 23 Risk factors Description of risk Ratinga of Mitigation measures Ratinga of risk residual risk In spite of efforts to increase the role of women in society, a wide gender gap prevails. Female genital mutilation (FGM) is a major social development challenge. Irrespective of the law against FGM practice, it still poses a challenge. Country engagement The Bank has limited leverage in Djibouti, due to a limited Moderate The Bank's program focuses Low with World Bank IDA allocation. However, the Bank plays a catalytic role in on a few sectors, and builds on mobilizing other donors. co-financing partnerships to leverage the Bank's influence. The portfolio of projects is healthy with an overall satisfactory performance. The Country Assistance Strategy (CAS) was endorsed Lending to Djibouti for the past three fiscal years averaged by the Board in April 2009. about $6 million per year, and it focused on social sector and The CAS foresees a lending of infrastructure. about $6 million (provided in grants) per year for the next three years. Governance The public administration is weak and lacks the capacity to Moderate The Bank will continue its Moderate effectively provide the necessary public services; and inter- work with the Government to institutional coordination is also weak. strengthen its capacity, including on procurement and financial management. Systemic Corruption The 2008 transparency index compiled by Transparency Moderate The Bank is providing Low international ranks Djibouti 102nd out of 180. technical assistance under the Governance and Anti- Inflow of FDIs remains high. Corruption (GAC) program to fight corruption. Technical assistance has been provided in the areas of procurement, budgeting, and 24 Risk factors Description of risk Ratinga of Mitigation measures Ratinga of risk residual risk auditing. Other (for example Djibouti is located in an unstable region which has Moderate The Bank cannot directly Moderate security risks, experienced many wars and civil unrest. As a result, refugee offset this risk but will work political/election risks) population in Djibouti is high. This creates tensions on closely with other already scarce national resources (food, water, areas for development partners to grazing). monitor developments and respond to increased risks or possible openings. II. Operation-specific Risks Technical/design The interventions planned are simple and the approaches have Low Detailed design and cost Low been previously tested estimates will be closely supervised Implementation ADDS has had a good start, it is fully staffed and organized, Moderate The Bank cannot directly offset Low capacity and operational manuals are in place, and project coordinators are this risk but will work continue sustainability in charge of the various projects. The only risk is a change of to work closely with ADDS to management which could undermine the good results support its institutional achieved so far strengthening through the third project component (training, management tools, M&E) Financial management - FM responsibilities entrusted to ADDS are complex. Substantial -Operational manual is Moderate developed with the support of - Lack of responsiveness regarding action plan that would be the Bank. agreed during supervision missions. 25 Risk factors Description of risk Ratinga of Mitigation measures Ratinga of risk residual risk ·The Monitoring and - Risk of Non compliance with Bank Guidelines Information System will be revamped with support of the current project. ·Close Bank supervision of the project. ·Reinforcing of the external audit function Procurement -A procurement unit has been established and consists of one Substantial -Update regularly the Moderate qualified and trained staff and one qualified and trained procurement plan; assistant -Poor quality of procurement planning due to the lack of early - Use the information system identification of the beneficiary's needs (software) integrated with financial management; -Lack of experience in procurement of most of the technical staff -Training will be provided to all managers at ADDS; -Lack of capacity of the suppliers given the size of the contracts -Continuous training will be provided to the procurement unit. Social and No resettlement is envisaged, and expected social and Low -Supervision will continue to be Low environmental environmental impacts are positive. In addition ADDS has close safeguards developed a new and improved operational manual, which contains detailed chapters to guide its staff in dealing with -ADDS will place a small unit social and environmental safeguards permanently in the neighborhood in order to be closer to the project and the community - Cost of the measures 26 Risk factors Description of risk Ratinga of Mitigation measures Ratinga of risk residual risk (mitigation and monitoring) and indication of sources of fund to be added to current EMP Other (for example cost Insufficient operation and maintenance of the built Substantial -Involvement of the community Moderate escalation, prevalence infrastructure in the project from the of failures in similar beginning increases ownership projects, adverse external developments -ADDS will prepare affecting costs/benefits maintenance protocols when of the project) completing infrastructure works, and will hand those, through open ceremonies to the corresponding agencies III. Overall Risk (including Reputational Risks) Moderate Memo items: 1. 2008 CPIA ratings (overall and four clusters) 2008: Overall: 3.1 a. Economic Management: 3.0 b. Structural Policies: 3.7 c. Policy of Social Inclusion/Equity: 3.0 d. Public Sector Management and Institutions: 2.8 2. IEG rating (% of projects rated unsatisfactory--MU, U, or HU--over last five years both for the country portfolio and the sector): MNA: 15.8%, Djibouti: 0% 3. Other governance and corruption indicators such as those prepared by WBI and Transparency International: Transparency International 2008 Corruption Perceptions Index: 3.0 (rank: 102 out of 180) WBI indicators 2008 Governance Indicator Percentile Rank Governance Score (0-100) (-2.5 to +2.5) Voice and Accountability 16.3 -1.12 Political Stability 37.8 -0.13 Government Effectiveness 14.2 -0.98 Regulatory Quality 22.2 -0.75 Rule of Law 35.4 -0.54 27 Risk factors Description of risk Ratinga of Mitigation measures Ratinga of risk residual risk Control of Corruption 45.4 -0.33 Source: www.transparency.org, http://go.worldbank.org/AL5SDP3T90 a Rating of risks on a four-point scale (High, Substantial, Moderate, Low) according to the probability of occurrence and magnitude of adverse impact. 28 Annex 3 Detailed Description of Modified or New Project Activities Activity Description Estimated cost USD Component 1: Improvement of Infrastructure Total 1,620,000 Roads - Rehabilitation of Road 39 and 57 722,500 - Street Lighting and reinforcement of hubs Drainage - Rehabilitation of 300 m of buried culvert under road type E, for storm water 351,600 drainage and its connection to the west desalinated canal. - Rehabilitation 1200m of buried culvert under Nasser/Guelleh batal avenue - Rehabilitation of 300m the buried Q7 internal networks (bd 51, AV42, BD 50, AV 39) - Construction of 100m of asbestos conducts Technical Studies and execution Including the following spaces : 348,750 works of a two floor health center - Maternity/child care - Emergency - Radiology unit - General Consultations - Lab - Dental care - Management offices Multipurpose playground west of Building a multipurpose playground with a 4 small shops complex and public 107,400 Q7 with commercial spaces on the toilets Type E road Building a showroom One floor showroom 50,000 Landscaping public spaces in Q7 plantation works in : 40,000 - The CDCs - The playground areas - Children playground Component 2: Community Development Total 195,000 Recruitment of an animator for Q7 + fees + materials and office rental 50,000 Social Awareness and mobilization Organization of meetings with the commune Q7 youth support program Increasing access to education for a larger number of youth at Q7 60,000 Complement to the Hygiene and Provide garbage collection, equipment supply, disposal stocking and pickup. 30,000 29 public environment component Other activities Committed Activities related to the PSAI without proper funds 55,000 Component 3: Technical Assistance Total 679,000 Engineering Designs Engineering designs for the above mentioned works 50,000 Project management Extension of project manager contract 84,000 Project impact study Complement for project impact study 40,000 Dissemination Complement for activities' dissemination 25,000 Financial Audit Complement for project's financial audit 30,000 ADDS Human-resource 50,000 Vocational training development Urban Planning 400,000 ADDS Fees 168,000 Unallocated budget 238,000 TOTAL 2 900 000 30 Annex 4 Revised Estimate of Project Costs Cost with Original COST (in Changes with AF (in Revised Cost (in PROJECT COMPONENTS REALLOCATION US$) US$) US$) (US$) COMPONENT 1: IMPROVEMENT OF 1,600,000 1,452,000 1,620,000 3,072,000 INFRASTRUCTURE Street rehabilitation and drainage 626,000 626,000 999,100 1,625,100 Street lighting 85,000 85,000 75,000 160,000 Sanitation 312,000 164,000 0 164,000 Construction and equipment of Community 362,000 362,000 0 362,000 Development Center Rehabilitation of public garden and sports ground 215,000 215,000 147,400 362,400 Construction of a Health Center 0 348,750 348,750 Construction of Macons' showroom 0 50,000 50,000 COMPONENT 2: COMMUNITY 350,000 498,000 195,000 693,000 DEVELOPMENT Literacy and post-literacy campaigns 80,000 80,000 55,000 135,000 Vocational training 113,000 113,000 60,000 173,000 Strengthening the capacity of community 57,000 57,000 50,000 107,000 associations Environmental management and community 90,000 238,000 30,000 268,000 hygiene Support to Boulaos Commune 10,000 10,000 0 10,000 COMPONENT 3: TECHNICAL ASSISTANCE 426,000 426,000 679,000 1,105,000 Technical studies and works supervision 128,000 (NO CHANGES) 50,000 178,000 Socio-economic and baseline survey 30,000 0 30,000 Project impact study 30,000 0 30,000 Financial audits 30,000 30,000 60,000 Support to community development 40,000 0 40,000 Capacity building of ADDS staff 50,000 50,000 100,000 Consulting services prior to effectiveness 18,000 0 18,000 ADDS Management Information System 100,000 0 100,000 31 Project dissemination 0 25,000 25,000 Project management 0 84,000 84,000 Project follow-up and evaluation 0 40,000 40,000 Urban Planning 400,000 400,000 ADDS fees 180,000 180,000 168,000 348,000 TOTAL BASELINE COSTS 2,556,000 2,556,000 2,662,000 5,218,000 UNALLOCATED 444,000 444,000 238,000 682,000 TOTAL FINANCING REQUIRED 3,000,000 3,000,000 2,900,000 5,900,000 32 Annex 5 Safeguards Policy Issues Environmental Safeguards In accordance with World Bank Safeguard policies on the environment (OP/BPGP/4.01), the project has been assigned a "Category B" rating as no adverse long- term impacts are anticipated. The rating is based on the conclusions of the Additional Finance appraisal, and was reconfirmed after completion of the Environmental Impact Assessment (EIA). The Bank's Safeguard Policies (OP/BPGP/4.01) have been made available to the PMU Director, and Terms of Reference for an EIA were developed under the Bank's overall guidance. The EIA was conducted by a Djiboutian consultancy firm. The study: (a) evaluated the project's potential environmental risks and impacts in the target area; (b) assessed project conformity with national as well as Bank standards and legal requirements; and (c) provided the executing agency, ADDS, with an action plan for project development in harmony with the natural environment, including monitoring tools to assess positive impacts under the project. The main objective of the Djibouti Urban Poverty Reduction Project (DUPREP) is to increase access to basic economic and social infrastructure and to community development opportunities within Quartier 7 in the city of Djibouti. The project has three components as follows: (a) improvement of infrastructure; (b) community development; and (c) technical assistance. An EIA has been prepared by ADDS for these three components and it includes a Framework for the Environmental and Social Management Plan (ESMP framework). EIA: The EIA for DUPREP concluded that the positive impacts from the project would far exceed the minor and temporary negative environmental impacts which will occur during the construction phase. Mitigation measures for such impacts, as advised, have been incorporated into the bidding documents for the infrastructure works to ensure that the measures are implemented by the contractors under the supervision and monitoring of ADDS. The EIA was prepared in accordance with the project document (WB Report n° 41999-DJ) for the economic and social impacts, beneficiary consultations organized in focus group sessions, and the results of project feasibility studies for environmental aspects. Findings from the Socio-Economic Analysis: Quartier 7, the largest and one of the poorest neighborhood in the city, is characterized by a very low level of access to basic services, the prevalence of informal housing, poor health indicators, low levels of educational attainment, high rates of illiteracy, and high levels of unemployment. 33 Findings from the Beneficiary Consultations Report: A total of 153 households were interviewed as part of the socio-economic study of the project. Several focus groups took place during this process, paying special attention to two variables, gender and age. The objective of the beneficiary consultations were to: (a) raise population awareness on project components; (b) mobilize the largest number of individuals as active participants; (c) facilitate exchanges with association representatives on major constraints and perspectives; and (d) emphasize the importance of a participatory approach in neighborhood projects. The major findings of those consultations were: (a) the importance of public street lighting to deter criminal and drug trafficking activities; (b) to address issues of unemployment; (c) to improve waste management and other hygiene issues; and (d) to assess the duration of infrastructure works. EIA findings: Project impacts were analyzed during different phases of the project cycle: (i) preparation, (ii) works, and (iii) operations. (i) Preparation: The EIA identified two environmental issues during the preparation phase. (a) Pavement choice for street rehabilitation: asphalt requires the use of heavy machinery which could damage neighboring houses and destabilize ground infrastructure. Cement and stone pavement, more expensive and labor intensive alternatives, would adapt better to unstable soils, but require much longer work and installation periods, possibly creating disturbance for local residents. The EIA concluded that asphalt would be the fastest and cheapest alternative, while reserving the cement and stone pavement alternatives for delicate and non-machinery accessible areas (narrow streets, unstable grounds, etc). B) Health Center (HC): Quartier 7 lacks a health center and has the city's worst health indicators. The construction of an HC in a central and accessible area of Quartier 7 will help improve health conditions in the neighborhood. The HC will be similar to the HC in Quartier 2, retrofitted to the site in accordance with Bank environmental regulations on Security and Sanitation for Health Centers, especially those related to waste management activities. (ii) Works: The construction preparation activities could negatively impact both the natural and human environments, the majority of which will most likely be limited to and located outside the site, with the exception of certain pieces of equipment, machinery and building materials located on some paths. During the works phase, it will be necessary to protect the site from chemical soil pollution produced by construction machinery (maintenance, garbage, etc.). 34 In order to reduce the negative impacts of construction, the EIA proposes four key mitigation measures: (a) establishment of the setup area on the periphery of the neighborhood when possible, including construction of site facilities using prefabricated containers properly connected to water and electricity, and clearly defined stocking areas; (b) appropriate staff management procedures; (c) warning signage and restricted access to dangerous construction sites; (d) limited working hours, including prohibited work at night, unless during an emergency in order to reduce noise pollution; and (e) limited impacts on normal pedestrian and vehicle mobility within and into the neighborhood. Moreover, the works phase should result in positive impacts, especially increased employment through the recruitment of local labor during the construction period. (iii) Operation: The EIA concluded that the project has no significant negative environmental impacts. On the other hand, it will fill the basic infrastructure gaps with significant positive impacts, as described below: The project will lead to major drainage and road infrastructure improvements, limiting water stagnation and increasing the performance of the drainage system. The project will also increase household accessibility to proper sanitation through awareness and support for individual latrine upgrading. Additionally, the current solid waste management model in Quartier 7 is very bad. Waste is being partly dumped inside the neighborhood due to a bad collection procedure, and bad infrastructure accessibility, causing severe health problems especially in high temperature seasons. One of the project's outputs will be a multi-scenario proposal for suitable and replicable model for solid waste collection within the neighborhood using local micro-enterprises that will solve some basic waste management issues for Quartier 7 and will improve its environmental quality; waste will be directed to the city's waste disposal center in Doudah, 20 Km southeast of the city. The landscaping and provision of green spaces will also improve air quality and aesthetic appearance of the neighborhood. Legal and Institutional Framework. The obligations related to environmental management are determined by the national norms for environmental protection. In fact, Djibouti has a specific legal framework for environmental management including the of the "Loi Cadre 2000" and the 2001 decree which respectively prescribe environmental principles and concrete methods for an adequate project Environmental Impact Assessment. ADDS, as the implementing agency, has created a Manual for Environmental Management (EM) which is used in the context of projects funded by the World Bank 35 and other international donors. ADDS performance in this area has been satisfactory, having developed environmental impact studies for a large number of small works in previous projects: Social Development and Public Works Project, 1999-2004, including additional finance, and Flood Emergency Rehabilitation Project, 2004-2009, including additional finance. Prior to the launch of works, contractors are required to address the impact assessment to the urban and environmental management authority (Direction de l'Aménagement du Territoire et de l'Environnement) as well as the ministries involved in the project, who will intervene in case contractors do not comply with their regulations. Review and Clearance of the EIA and EMP. The EIA and EM have been reviewed and cleared for disclosure by the Bank's Regional Safeguard Advisor. All documents have been disclosed both in the Bank's Info Shop and in Djibouti as of April 23, 2010. Any updates of those documents will be similarly disclosed. Social Safeguards No social safeguard issues are expected to be triggered by the project. It was agreed that all work be carried out on public land will not result in population displacements nor disruption of economic activities. In addition, the EIA includes a full evaluation of social safeguard issues, including the existing legal framework and on-site verification. 36