INTEGRATED SAFEGUARDS DATA SHEET APPRAISAL STAGE Report No.: ISDSA3036 Public Disclosure Copy Date ISDS Prepared/Updated: 31-Mar-2013 Date ISDS Approved/Disclosed: 02-Apr-2013 I. BASIC INFORMATION 1. Basic Project Data Country: Bangladesh Project ID: P120583 Project Name: Bangladesh Modern Food Storage Facilities Project (P120583) Task Team Masood Ahmad Leader: Estimated 29-Mar-2013 Estimated 23-May-2013 Appraisal Date: Board Date: Managing Unit: SASDA Lending Specific Investment Loan Instrument: Sector: Crops (60%), Agricultural extension and research (20%), Public administration- Agriculture, fishing and forestry (20%) Theme: Nutrition and food security (50%), Natural disaster management (25%), Other public sector governance (25%) Financing (In USD Million) Total Project Cost: 300.00 Total Bank Financing: 275.00 Public Disclosure Copy Total Cofinancing: Financing Gap: 0.00 Financing Source Amount BORROWER/RECIPIENT 0.00 International Development Association (IDA) 275.00 Bangladesh MDTF for Climate Change 25.00 Total 300.00 Environmental B - Partial Assessment Category: Is this a No Repeater project? 2. Project Objectives The overall Project development objective is to increase the grain reserve available to households to meet their post-disaster needs and improve the efficiency of grain storage management. 3. Project Description The project will preliminarily comprise the following components: Page 1 of 10 Component A – Construction of Modern Grain Storage Silo Facilities (US$250 million) Public Disclosure Copy This component would support: (A1) construction of Public Storage Facilities with a capacity of about 0.6 million tons in the form of modern grain storage silos; and (A2) provision of household level storage facility or family silos particularly in the disaster prone areas of the coastal zone for about 1.25 million households; and (A3) implementation of social and environmental management plans. Component A1: Construction of Modern Public Food Grain Storage Silos (US$210 million). This component would finance an improved storage silo system to store milled rice with a tot1al capacity of around 600,000 tons. The silos would be constructed on about 8 sites all over the country. All sites have land currently owned by the DG-Food and vacant public land. No new sites would be undertaken in this first phase project. Component A2: Household (HH) Silos (US$25 million): Household level silos or grain storage bins are specially designed for fiber glass cans that can take about 70 Liter (40 Kgs) of rice with a water tight lid (for detailed specifications of the HH Silos see PAD). Once rice is stored, the seal tight lid prevents the contents from damage due water from surges and floods. These silos are being provided to people in Sidr-affected areas and they are extremely popular. People use them to store rice seeds (which is more valuable than rice) for safekeeping of critical inputs for future planting seasons, in the event of floods or storm surges, as well as for rice storage. The cost of such a Silo is about US$30. The project would make this Silo available at a discounted price of US$10 per piece for households. The manufacturers would be encouraged to produce such silos, and eligible households would be able to purchase them at a discounted price through a voucher system, administered by project consultants and contracted NGOs. Selected households would receive a voucher based on agreed criteria (such as in coastal areas, with certain income levels, etc) and would ensure that only one silo is purchased at half price per household. It is estimated that about 1.25 million household silos would be provided under the project, creating about 125,000 tons of storage of rice seed (or rice) in Public Disclosure Copy surge-prone areas of the coastal zone. Though the cost per ton for such storage is higher than the large public silos, the high transportation and distribution costs of grain to very remote areas immediately following a disaster makes this strategy the most effective. In addition, it also reduces the burden of the government to carry such stocks (which blocks a lot of funds that could be used for development) and fairly distribute in remote areas. Finally, the ability to store rice seeds for the next agricultural season provides an additional value to households. Component A3: Implementation of Social and Environmental Management Plans (US$15 million): The sites selected for public silos are already owned by the Government. Therefore, no major social or resettlement issues are expected. However, in order to ensure that, if any such issues arise, they could be addressed. These issues could be, for example, increased traffic congestion, or environmental or social issues that could emerge during construction of silos. Also, the component would support the enhancement of the environment, such as improved landscaping, plantation of trees to improve the aesthetics of tall steel silos, etc.. Component B – Support for Food Planning and Monitoring Program (US$25 million) Improvements are needed in the monitoring and management of food storage/stock and this system needs to be modernized. This component would finance these improvements and introduce a modernized system that would assist the Government of Bangladesh in better planning and Page 2 of 10 monitoring of food stocks. These investments would assist in significantly reducing losses, and would ensure a timely distribution network for grain stocks in the event of an emergency. In general, FPMU acts as a central coordinating authority and information clearing house for all food security Public Disclosure Copy related policy and program activities. FPMU could intervene more actively to improve the DG- Food’s management information systems and reporting of rice and wheat distribution under all the different schemes include those designated for disaster relief. Right now it is apparent that there is no division level data generated for these programs. The information system would help in improve the transparency and accountability of the entire food distribution system. This component would also support carrying out studies and thus provide a framework for dialogue on improving the food distribution and stock turn over policies. Currently, the food distribution system suffers from several weakness and governance issue many of them arise from the quality of rice that is released from the godowns. With improved quality of stock due to better storage facilities the Government may be able to turn over the stock by auctioning the rice in the market that would get high price and thus reduce the government cost of purchase and storage of rice. The component would support various studies and preparation of policy notes that help answer key questions regarding stock turn over and food distribution arrangements. This would also help in devising policies and instruments for efficient management of the grain stocks in the country with reduced burden on the Government’s budget. This component would have two parts (B1) related to planning and coordination with other entities and Ministries which will be implemented by the DG FPMU in close collaboration with the DG Food and other relevant Ministries such as Agriculture; and (B2) related to food stock monitoring and movement and release etc., which would be implemented by the DG Food in close coordination with DG-FPMU. Component C - Project management, construction supervision, technical assistance, training and strategic Studies. (US$25 million) Public Disclosure Copy This component would finance costs associated with: (C1) project management of the task, incremental staff and expenditures of the DG Food in implementation of the Project, the costs for implementing the Governance and Accountability Action Plan (GAAP), including a panel of experts, as needed, a procurement panel, audit and other such costs; (C2) cost of consultants for construction supervision and designs required during the construction. This would include costs for construction supervision, monitoring and evaluation of project impacts; (C3) provision of technical assistance, training, institutional capacity building, preparation of future projects, and any strategic studies needed during project implementation. This component would build the capacity of DG-Food A to effectively implement the Project, O&M of the food storages t manages, and fully carry out its mandated functions. These activities would include, but not be limited to: (a) enhancing DG-Food’s capacity in planning and programming, engineering and O&M of the storages, financial management, procurement, and management of environmental and social issues; (b) technical assistance and training in such areas as designing of silos and storages, detailed designs of structures, contract administration and construction supervision, procurement, operations and management planning, asset management plans, financial management, and legal issues (such support would include on-the-job training, post-graduate programs, seminars, workshops, and study tours, etc.); (c) implementation of the governance and accountability action plan (GAAP); and (d) an independent panel of experts (IPOE) for design and construction quality, safety enhancement or any other issues that may have to be addressed during Page 3 of 10 Project implementation. It would also support the strengthening of DG-Food’s capacity in devising strategies to minimize the Public Disclosure Copy cost of grains storage, effective distribution policies and practices with strong technical expertise and governance culture. Some of these activities will be carried out in conjunction with the work under component B. This support would include, but not be limited to: (a) development of financing strategies for grain storage, (b) review of the medium-term investment program, development of the long-term investment program and identification of a financing strategy, including areas of potential interest to the private sector; (d) review of the existing institutional, legal and administrative framework for financing grain storages and development of proposals for upgrading based on international best practices; (e) development of potential modalities for public private partnership (PPP) taking into account possible support from the Government, donors etc. (f) asset ownership, benefit-sharing alternatives, etc., and the definition of the public sector’s financing role to complement/support potential private investments; (h) strengthening of DG-Food’s financial and management capacity; and (i) support for improving governance and internal controls. 4. Project location and salient physical characteristics relevant to the safeguard analysis (if known) The possible 8 locations for the Modern Grain Silo under the project are Barisal, Narayanganj, Dhaka, Ashuganj, Madhupur, Mymensing, Maheshwar Pasha and Chittagong. The sites already possess conventional godowns. Most of the sites have enough extra space to fit the new silo cluster. Although most of the sites are already developed, new technology construction and deployment may require land filling and put pressure on utility supply like gas and electricity. Dhaka site will require demolition of existing structures. Location for stacking of demolished debris and management should be planned beforehand. The drainage and sewerage facility may also need to be enhanced. For the Madhupur site, to the east of the plot, Government khas land under District Commissioner is available for any construction. As the land was lying vacant for long, the local people are informally using the land for banana and pineapple cultivation. The land can be vacated with a cease and desist initiative by the local administration at the request of the DG-Food allowing the informal users such Public Disclosure Copy time to harvest from all matured banana plants. Any change of site boundaries, may involve social safeguard compliance issues. 5. Environmental and Social Safeguards Specialists Nadia Sharmin (SASDC) Md. Akhtaruzzaman (SASDS) 6. Safeguard Policies Triggered? Explanation (Optional) Environmental Assessment OP/ Yes Modernizing the current food storage system in BP 4.01 the country will result in improved storage capacity, and could mean an increase in traffic in the areas surrounding the silos, as more grain trucks move in and out of the storage facility. Land filling may be required at some sites during construction of the Silo. Gas and electricity consumption will increase during the construction and operational phase. The capacity of existing sewerage and drainage system may need to be enhanced or needs to be established. Since new Page 4 of 10 technology will be introduced, adequate safety measures should be followed during construction and operation phase. Public Disclosure Copy An overall environmental assessment of possible sites is underway and Environmental Management Framework (EMF) for the project is already under preparation. The site specific Environmental Management Plan will be developed. Natural Habitats OP/BP 4.04 No Forests OP/BP 4.36 No Pest Management OP 4.09 No Physical Cultural Resources OP/ No BP 4.11 Indigenous Peoples OP/BP 4.10 No The project will cover the entire country. The indigenous peoples and communities are dominating in number in the Chittagong hill districts but a small proportion of them are also present in most of the plain districts. The project will consider “impact on indigenous communities� as an exclusion criterion for financing. The sites reviewed for construction of silos are devoid of IPs and the first phase sites Public Disclosure Copy have no social safeguard compliance issues. The exclusion criteria and social inclusion framework will be included in the project’s Social Management and Resettlement Policy Framework (SMRPF). Involuntary Resettlement OP/BP Yes If any resettlement issue arises during detail 4.12 design OP 4.12 may trigger. The Environment and Social Assessment and Management Framework includes the Social Management and Resettlement Policy Framework to address the issue in future. Safety of Dams OP/BP 4.37 No Projects on International No Waterways OP/BP 7.50 Projects in Disputed Areas OP/BP No 7.60 Page 5 of 10 II. Key Safeguard Policy Issues and Their Management A. Summary of Key Safeguard Issues Public Disclosure Copy 1. Describe any safeguard issues and impacts associated with the Restructured project. Identify and describe any potential large scale, significant and/or irreversible impacts: The project will involve civil work and demolition of structure. Occupational health and Safety is the major concern for construction and operation of steel silo. The construction activities will involve operation of heavy construction machinery, vehicular traffic, excavation, filling operations and demolition of structures. These activities may pose some safety hazards to the local population. The fuel storage at the camp sites may also pose safety hazards for the construction staff as well as for surrounding population. Stockpiling of construction material in all sites and debris from the demolished structure may cause serious accident to the construction worker and people in the vicinity. Construction of steel silos may pose significant hazards related to the potential fall of materials or tools. Although, chilling system will be introduced for storage to mitigate infestation, the silos may need to use fumigants in emergency or for long term storage. Although DG-food is using fumigants regularly and steel silo is expected to minimize or avoid the use of fumigants, in case of use of fumigant should be according to the USEPA and WHO guideline. Environmental Health and Safety measures should strictly be followed for O&M of Silos. During construction phase, around 450 trees will be cut from the 8 sites. To address this issue the contractor should prepare a tree plantation plan. The project will create noise and vibration in the surrounding due to a wide number of pile driving, at Dhaka and Mymensing, demolition of structure will cause severe dust pollution. In addition Construction machinery and project vehicles will release exhaust emissions. The high tech modern silo will require continuous power supply. Key social issues relating to project implementation are: (i) avoiding adverse social impacts in site selection, design and implementation; (ii) participation by project functionaries, business groups, Public Disclosure Copy NGOs, civil society and local communities; (iii) inclusion, particularly of the poor and vulnerable sections including ethnic minorities; (iii) identification of unavoidable adverse social impacts and mitigation; (iv) social conflicts and grievances during construction; (v) capacity building of key local stakeholders; (vi) addressing gender issues and community needs; and (vii) communication to address these issues. None of the sites for civil works will be carried out in private land but within existing land reserve of the DG-Food except in Tangail, where a new site has been selected for construction of the public silo in Madhupur. Given that this land in Madhupur is a khas land (government owned land) no private people will be impacted. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area: The project does not have any plan for installlation of any small scale power plant for ensuring continuous power supply or any other back up plan for power supply. However, the project will require identification of sources for continuous power supply beforehand for ensuring continuous power supply to the silos. If any physical activity is considered for ensuring power supply during project period, the implementing agency will require conducting separate Environmental and Social Impact Assessment at the project sites. 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. Page 6 of 10 The alternative analysis for BMFSP has been conducted into the following points (a) "No Action" alternative of the project. (b) Alternative Analysis for Selection of Sites and (c) Alternative Analysis for Technology Options. It has been found the current storage capacity of the Public Disclosure Copy country is 16 lakh tons. But it will be reduced to 13 lakh Tons by 2013 due to further deterioration of the old godowns. It is estimated that the requirement of storage capacity for food grain will be 30.5 lakh tons by the end of 2020. If the storage facility is not increased immediately with the increasing frequency of natural disaster, decreasing storage facility due to deteriorated existing godowns, the country will face shortage of food during emergencies. Fourteen sites were initially taken into account for review. Considering the above conditions, 8 sites have been selected for the project. The site selection criteria are as follows: a. Strategic value of the storage location for distribution of food grain stocks in emergency relief situations or for the pre-positioning of such stocks b. Rationality of increased storage capacity at the site based on existing and anticipated food grain movements by the client for all uses in order to ensure proper rotation of stocks c. Avoidance of land acquisition issues that could delay the start of construction and therefore a focus on existing Food Department storage sites. Based on the above listed criteria and environmental and social aspect Barishal CSD, Narayangan CSD, Dhaka CSD, Mymensing CSD, Maheswarpasha CSD, Ashuganj silo, Chittagong Silo and Madhupur site have been selected for modern food grain silo construction. Technological benefits for Steel Silo, concrete silo and conventional godowns were also assessed in this report. It has been found that Steel Silo provides the best scenario in terms of temperature and moisture control, space requirement, dust control and rodent control. However, steel silo requires high skill set for construction and operation. Public Disclosure Copy 4. Describe measures taken by the borrower to address safeguard policy issues. Provide an assessment of borrower capacity to plan and implement the measures described. The project will be implemented by the Ministry of Food (MoFood), which has the sole mandate to manage food grain stocks in the country and ensure their availability according to National Food Policy of 2006. MoFood will have the overall responsibility for the project implementation (through its DG Food). MoFood will implement the Bank funded project for the first time in recent years, they are not familiar with the Bank safeguard policies. Given the nature of project interventions and the types of environmental and social impacts captured in the environmental and social assessment, DG-Food has prepared a detailed Environmental and Social Assessment and Management Framework (ESAMF) report including environmental management framework (EMF), environmental management plan (EMP) and social management framework (SMF). The ESAMF provides policy and institutional framework to guide DG-Food in addressing environmental and any social safeguard compliance issues during implementation. Although there is no social safeguard compliance issues with the eight sites selected for the silo construction, the ESAMF is available with DG-Food to address any unforeseen safeguard issues during implementation. The PMU will have a dedicated Senior Environmental Specialist (SES) to ensure implementation of EMP and other environmental management responsibilities. The SES will maintain liaison with Page 7 of 10 WB safeguards team, regulatory agencies, and other stakeholders during the Project implementation. The Senior Environment Specialist has to be on Board as soon the PMU is set up. S/He will be responsible for ensuring the adequacy of environmental component in the Public Disclosure Copy Bidding Document (BOQ) and ensure the quality of Environmental Action Plan (EAP) submitted by the contractor. The field level environmental specialist should be on board before commencement of the field work. The PMU will also have a Senior Social Specialist (SSS) to ensure application of the SMRPF for social safeguard compliance of the project interventions. The construction contractors will have dedicated properly qualified and experienced, site-based Environment Supervisors (ESs) at each construction site. The ESs will be responsible to implement various aspects of the EMP particularly the mitigation measures to ensure that the environmental impacts of the construction works remain within acceptable limits. The Supervision Consultants will have dedicated, properly qualified and experienced, site-based Environment and Social Monitor (ESM) at each construction site. The ESMs will monitor and supervise implementation of EMP and SMP at the field level. The (Health, Safety and Environment) HSE function will be a key element of the operation and maintenance arrangements at each of the silo facility. Dedicated HSE personnel will be part of the O&M staff and will be responsible to prepare and then implement the relevant parts of the Operations Manual for ensuring health and safety during project operation. 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. The population in the disaster prone areas of Bangladesh is the prime beneficiary of the project and they are spread all over the country, in the coastal zone, in the flood prone areas, and in the drought prone areas. Concentrated to the proposed silo sites, the residents attached to the 8 selected sites will be impacted during construction and operation of the silos facilities. Local leaders, traders, millers, transporters and wage laborers have expressed their interest to the project. Public Disclosure Copy The project stakeholders including women and vulnerable groups were consulted at two steps; once during identification of the sites for public silo facilities and again after finalization of the eight sites for construction. Community meetings and consultation with local peoples at the sites were conducted. The consultants and the DG-Food staff at the local level organized and conducted the community meetings and the consultant discussed various pertinent issues with the local community representatives during site selection. Outside the silo sites, communities in two villages in Patuakhali were also consulted on current practice of grain storage at the family level and need for interventions for improved and safe storage facilities. Consultation during site identification: Consultation with local communities and institutional stakeholders were carried out at all potential sites in Barisal, Narayanganj, Dhaka, Ashuganj, Madhupur, Mymensingh, Maheshwar Pasha, Chittagong, Mongla, Dinajpur, Naogaon, Bhaghabari, Khulna, and Govindaganj. Key issues discussed in the community level during site identification were (i) project objectives and intended benefits, (ii) project components related to silo facilities, (iii) need for participation of the communities in site selection and project design, (iv) criteria for site selection, (v) likely impacts on assets and income, (vi) provision of national law and the Bank policy on social safeguards and (vii) possible mitigation measures The consultations brought forth that despite some adverse impacts of the project, the communities were very positive towards the project. They feel proud of having a project of national importance in their area. Page 8 of 10 Consultation at eight sites: Site level consultation was carried out after final selection of sites for eight silo facilities during January 2013 in Dhaka, Narayanganj, Comilla, Chittagong, Tangail, Public Disclosure Copy Mymensingh, Khulna and Barisal sites. A total of 387 men and women including traders, transport workers, wage labors, farmers, unemployed youths, transport operators, farmers, millers, teachers, religious leaders, elected representatives, dealers, service holders, students, mechanics, rickshaw pullers, autorickshaw drivers, trade union leaders, and port traders participated in the discussion at the eight sites. The communities at the eight selected sites understand that construction for civil works may involve sudden increase of migrant labourers at the construction sites. The influx of the non-local workers may pose a threat to the local public health environment if safe work environment cannot be maintained. Employment of local labourers will be more safe on health concerns. Consultation at village level in Patuakhali: The coastal zone including Khulna, Barisal and Patuakhali districts are prone to natural disasters like cyclones and tidal inundations. Communities in two different villages in two unions in Patuakhali were consulted during January 2013 to understand the current practice and problems with family level grain storage. The villages were visited by the local DG-Food officials and consultants on 3 January 2013 and had meetings with the communities there. A total 143 persons in two villages including local elected representatives, farmers and women participated in the consultation meetings. The community practice on grain storage at household level and their choice and expectation on the family silo bins were understood during the consultation. Disclosures: Detailed ESAMF reports, including stakeholder consultation deliberations, are available with the PMU. Impact Assessment checklists and the simple social screening matrix, prepared as a part of the project preparation, are also available with the PMU. The ESAMF on policy issues and impact mitigation measures has been translated into Bengali language and disseminated locally. In accordance with the Bank’s disclosure policy, the ESAMF is uploaded in the DG-Food’s website and in the Ba nk InfoShop. Any subsequent EMP/SMP/RAP has been and Public Disclosure Copy will be discussed locally with the stakeholders and disseminated widely and made available on the project’s portal and in the Bank InfoShop before award of civil works contract. B. Disclosure Requirements Environmental Assessment/Audit/Management Plan/Other Date of receipt by the Bank 12-Mar-2013 Date of submission to InfoShop 31-Mar-2013 For category A projects, date of distributing the Executive Summary of the EA to the Executive Directors "In country" Disclosure Bangladesh 12-Mar-2013 Comments: Resettlement Action Plan/Framework/Policy Process Date of receipt by the Bank 12-Mar-2013 Date of submission to InfoShop 31-Mar-2013 Page 9 of 10 "In country" Disclosure Bangladesh 12-Mar-2013 Comments: Public Disclosure Copy If the project triggers the Pest Management and/or Physical Cultural Resources policies, the respective issues are to be addressed and disclosed as part of the Environmental Assessment/ Audit/or EMP. If in-country disclosure of any of the above documents is not expected, please explain why: C. Compliance Monitoring Indicators at the Corporate Level OP/BP/GP 4.01 - Environment Assessment Are the cost and the accountabilities for the EMP incorporated Yes [ ] No [ ] NA [ ] in the credit/loan? OP/BP 4.12 - Involuntary Resettlement If yes, then did the Regional unit responsible for safeguards or Yes [ ] No [ ] NA [ ] Sector Manager review the plan? The World Bank Policy on Disclosure of Information Have relevant safeguard policies documents been sent to the Yes [ ] No [ ] NA [ ] World Bank's Infoshop? Have relevant documents been disclosed in-country in a public Yes [ ] No [ ] NA [ ] place in a form and language that are understandable and accessible to project-affected groups and local NGOs? All Safeguard Policies Have satisfactory calendar, budget and clear institutional Yes [ ] No [ ] NA [ ] responsibilities been prepared for the implementation of measures related to safeguard policies? Public Disclosure Copy Have costs related to safeguard policy measures been included Yes [ ] No [ ] NA [ ] in the project cost? Does the Monitoring and Evaluation system of the project Yes [ ] No [ ] NA [ ] include the monitoring of safeguard impacts and measures related to safeguard policies? Have satisfactory implementation arrangements been agreed Yes [ ] No [ ] NA [ ] with the borrower and the same been adequately reflected in the project legal documents? III. APPROVALS Task Team Leader: Masood Ahmad Approved By Regional Safeguards Name: Zia Al Jalaly (RSA) Date: 02-Apr-2013 Coordinator: Sector Manager: Name: Simeon Kacou Ehui (SM) Date: 31-Mar-2013 Page 10 of 10