Report No. PIC2898 Project Name Madagascar-Second Environment Program... Support Project Region Africa Sector Environment Project ID MGPA1537 Executing Agency Ministry of Environment National Environment Office Antananarivo, Madagascar Contact: Mr Joseph Andriamampianina Directeur General, ONE Telephone: (261-2) 9 99 Fax: (261-2) 306 93 Probable Cost US$180 million Proposed IDA Credit US$30 million Financing Plan To be discussed with other donors during joint appraisal expected contributions: GEF, UNDP, IFAD, USAID, Germany, Norway, France, Switzerland, Japan, European Union, WWF Lending Program FY 97 L Multi-donor Appraisal November 1995 and April 1996 Appraisal Date (WB) June 1996 Negotiations Date September 1996 Environment Category C 1. Background. The Malagasy economy is mostly natural resource-based. Madagascar has also been identified by the international conservation community as one of the ecologically richest countries on the planet. Nearly seventy five percent of its estimated 200,000 living species are endemic, i.e. found only on this remarkable island. Unfortunately, Madagascar is noted not only for its high degree of biological diversity, but also for increasing environmental degradation. According to available information, aost eighty percent of the country's original forest cover has disappeared, or has been severely degraded, mainly because of slash and burn agriculture. This also results in the loss of an estimated 200 tons of topsoil per hectare each year. The threats of deforestation, bush fires, and extensive cropping of marginal lands are removing the ground cover necessary to keep in place the highly erodible soils of this unusual land. This degradation threatens not only biological diversity, but watershed and soil stability vital to the agrarian economy. Reversing the downward spiral of environmental degradation would thus mostly benefit the poor, while maintaining exceptional biodiversity wealth. 2. Aware of these problems, the Government prepared in 1988 a National Environmental Action Plan (NEAP), with the support of a group of donors, international agencies and NGOs led by the Bank. The fifteen years program foresees a first five-year phase aiming at creating a proper policy, regulatory and institutional framework, a second phase aiming at the consolidation of the programs initiated under the first phase, and a third phase that would achieve the mainstreaming of environment into macroeconomic management and sector programs. 3. The first phase program is under implementation. It has the double objectives of beginning operations of an urgent nature while establishing the basis for the overall program, in terms of building institutions, developing human resources, establishing sound environmental policies, methods, tools and procedures. It consists of six components: (i) protecting and managing biodiversity at the level of fifty Protected Areas, testing concepts such as integrated conservation and development projects as a means to better conserve biodiversity; (ii) developing community-based soil conservation and watershed management mini-projects; (iii) developing land management tools through mapping and remote sensing; (iv) improving land security through cadastral operations; (v) promoting environmental sensitization, education and training, and developing environmental policies and procedures; and (vi) developing a support program including institution building, reinforcement of the environmental data base, marine and environmental research, monitoring and evaluation. Program implementation has been to a large extent through local and international NGOs. Despite the fact that progress on many components has been slower than anticipated initially, most of the projects objectives are being met. Some 20,000 families are benefiting from over 600 mini-projects for soil conservation work by ANAE (Association Nationale dActions Environnementales); twenty one national parks and other protected areas are being established and managed to the extent that ANGAP's (Association Nationale pour la Gestion des Aires Protegees) current funding allows; with nearly 200,000 ha surveyed, land titling has begun to have an impact in and around protected areas; FTM (National Geographic Institute) has significantly improved its mapping capacity and produced aerials photographs over 80,000 km2 of protected areas, and ONE (National Environment Office) has developed activities in promotion, video production, training, policy formulation and regulatory framework improvement. 4. A Forests Management and Protection Project (IDA Credit 1878-MAG) was also implemented to: (i) help the FANALAMANGA parastatal develop the Mangoro industrial plantation to a production level which would allow profitable exploitation. This component represented the third phase of the Bank's involvement in the forestry sector in Madagascar; and (ii) assist DEF (the Waters and Forests Directorate) in programming, forest exploitation control, assistance to villagers for reforestation, and expansion and protection of natural reserves. The implementation of the FANALAMANGA component gave satisfaction during the Project but the timber sales levels were insufficient to compensate for the poor results recorded during the first two phases and the ERR calculated the Project was found to be close to zero. DEF, for its part, experienced great difficulty in implementing the project, because of both management and technical deficiencies, and lack of a sector strategy. The situation improved significantly since the Project's mid-term review in 1992 with -2 - the reformulation of the Project to focus on forest inventory, the formulation of a new human resource policy and a new forestry policy. All activities initiated by the mid-term review and some new ones (the creation of new protected areas and the management of natural gazetted forests) were transferred in 1994 under the umbrella of the Environment Project, and are currently developing satisfactorily. The support to FANALAMANGA was terminated with the end of Credit 1878-MAG. 5. Lessons from the First Phase program (EP1). Main strengths include the effective development of institutions and partnerships, high visibility and a substantial demonstration effect, both domestically and internationally, and effective field results (see above). Weaknesses were a slow and uneven take-off, insufficient program integration, consolidated monitoring not yet operational, and an as yet insufficient role given to environment concerns when formulating policies that require hard choices, whether at national or local level. The most important lessons which can be drawn from the first phase of the Environment Program concern institutions, program scope and sustainability, and the importance of community involvement: (i) Institutions. The first phase of the environment program involved the establishment of several new institutions. Building capacity within these new institutions has taken time -- even more time than initially anticipated -- and has absorbed much of the efforts of this program. Although the impact of this work is difficult to measure, it is clear that key results have been achieved: ONE is well established in their role as both a coordinating and policy formulation agency; ANGAP and ANAE have developed a clear vision of their mission and their business is growing. Now that the various agencies have reached their cruising speed, clarifying their roles and mandates vis-e-vis Central Government agencies is essential; this has been spelled out in detail in a recently produced Manual of Inter-institutional Relationships. (ii) Program scope. One central idea behind the design of the first Environment Program was to integrate all activities which support the environment into a single program -- particularly those activities concerning biodiversity conservation, soil conservation and policy development. Although such an integration was only partially achieved, and the program is seen by outside observers as too imbalanced in favor of biodiversity conservation in protected areas, it helped foster priority-setting on a national scale and coordination of donor funding, as well as creating synergy between closely linked programs (e.g. improved land security as a means to improve soil, water and biodiversity conservation). However, another result of integrating all of these issues into the EP1 was the creation of an operation that was relatively complex for new institutions to manage. In the second phase, the rationale for maintaining such an integration is still the same. In addition, there are further environmental concerns which the Malagasy would like to address (e.g. improvement of marine and coastal environment, and improvement of environmental policies and norms in urban areas), as a follow-up to research and policy formulation under EP1. In order to maintain the Environment Program within the limits of the Government's ability to implement it, it will be essential to keep improving the existing management mechanisms as well as to implement the decentralization policy provided for under the new Constitution. As - 3 - sectoral programs increasingly take the environment into account, another challenge will be to determine which are the environment-related activities that should better be carried out within the context of sector programs and thus be left out of the Second Phase Program (EP2). (iii) Sustainability. The financial sustainability of some of the activities initiated under the EP1 is not clear. This is particularly the case for the Integrated Conservation and Development Projects which have been started in some of the Protected Areas, and it is intended to phase out this approach. Instead, EP2 would expand conservation activities beyond the selected protected areas into a more regional approach which better integrates environmental concerns into economic and sectoral planning. Under its current economic situation, Madagascar cannot afford to protect its biodiversity patrimony alone. The expected global benefits lead to necessary cost-sharing with the international community, hence the opportunity to use GEF resources. (iv) Community involvement. Another very clear lesson learned in the course of the first phase, is the importance of working with the communities affected in the preparation and implementation of any activity. The ownership created when communities are involved increases the pace of implementation, the positive impact on the environment and the sustainability of this impact. This is now widely recognized in the country, and it is anticipated that all future programs will rely heavily on local participation, particularly through the transfer of management responsibilities to local communities. 6. Program Objectives. The objectives of the program are to reverse current environmental degradation trends and to promote sustainable use of natural resources, including soil, water, forest cover and biodiversity. Another key objective is to create the conditions for environmental considerations to become an integral part of macroeconomic and sectoral management of the country. The program would be the second phase of implementation of the NEAP. It would continue and strengthen activities already launched under the first phase and initiate work in new areas where environment problems are important, as described below. Depletion of Madagascar's natural resource base can be reduced by changing the enabling policies, institutions, incentives, and other conditions so that resource users have the authority to manage their own resources, and the responsibility and incentives to do so in a sustainable manner. Environmental outcomes are the by-product of land use management and production decisions. In the absence of a land management and agricultural production policy, there is no viable resource conservation policy, because how people manage land and production options determines what they do with the forest. Therefore, the environmental strategy needs to increase the emphasis on rural development and smallholder land management on farmland and open access lands, especially in the areas where population pressure is the greatest, which are often far from the protected forests and parks, requiring strong sectoral links from the protected areas to the regional growth poles. The EP2 would complement the activities undertaken under several agricultural programs (extension, research, irrigation, livestock) that also aim at improving the management of natural resources at farm level; more generally, it would be a key part of a global development strategy that combines macro-economic stabilization, -4 - structural reform and the promotion of private sector investment and export-led growth. 7. Program Description. Although the Environment cannot be considered to be a sector (it is rather a dimension of problems that spans across all sectors), the Program described in this brief is part of a new generation of investment operations that follow an integrated sector approach, i.e. a SIP ( Sector Investment Programs). This approach, which aims at improving the effectiveness of public expenditures, has the following main characteristics: It covers all or most priority activities related to the environment It is prepared by local stakeholders It is supported by all donors active in the environment in Madagascar It minimizes reliance on international long-term consultants It involves common implementation arrangements 8. The program will essentially pursue, improve and expand the priority activities that have been initiated under EP1 by incorporating the lessons learned while minimizing new components. In addition, a process of problem analysis with a regional and local perspective was developed as part of EP2 preparation, together with work on the formulation of a number of key policies, namely decentralization and local management of natural resources, particularly forests, as well as on the need for mechanisms to promote synergy - both between EP2 activities and more generally with other development programs. In particular, the realization that biodiversity cannot be isolated from other environmental concerns has led to the development of a regional/local approach to biodiversity conservation under EP2 that would be complemented by agricultural and other income generating activities that also aim at improving the management of natural resources at the local level. This approach would be implemented within a context which fosters better integration with the ongoing decentralization process, rural development efforts and regional growth pole activities with a spatial definition beyond the narrowly defined peripheral zones of the protected areas. The design of the program takes into account the outcome of all this work. The program is now defined as three sets of components, corresponding respectively to field operations, strategic activities and support activities, as follows: Field operations would fall under two categories: Specialized sub-sector activities, corresponding to about two third of program cost, would be geared towards improved management of natural resources, including soil, water, forest and biodiversity, and would include: * Sustainable soil and water management; US$ 43.5 million (ANAE: 30.5; Ankarafantsika: 7.3, already financed; other watersheds: 5.7): Following the model developed under the EP1, ANAE would continue its decentralization process, expand its regional coverage and implement about 4,000 micro-projects under EP2. The focus would be on demand-driven, low-cost and locally adapted - 5 - intervention that can contribute to spontaneous adoption of improved practices by other farmers (multiplier effect). In addition, specific watershed management operations would be developed, either in cases were major investments need to be protected (e.g. Ankarafantsika and the Marovoay Plain) or on a small scale pilot basis (continuation of the work undertaken with FAO support on four watersheds in the Antananarivo Region). * Multiple-use Forest Ecosystem Management; US$ 29.9 million: New forestry policies have been formulated under the EP1, through a decentralized and highly participatory consultation process. The resulting strategy is to give back responsibility to local communities for the management of natural resources. Under EP2, a number of gazetted forests and community forests would be put under sustainable management. The process would include the following steps: (i) completion of the national ecological forestry inventory, and identification of new protected areas (300,000 ha); (ii) completion of on-going pilot forest management schemes (180,000 ha); (iii) participatory formulation of management plans, involving neighboring communities and the Forest Service (400,000 ha); and (iv) implementation phase, i.e. management of the forest for multiple use, in accordance with the management plan (150,000 ha under EP2, continuation under EP3). In order to ease pressure on the natural forest, the program would also encourage farmers and private enterprises to plant more trees, through land use planning and technical advise. Implementing such a program would also require reorganization as well as significant capacity building of the Forestry Service (DEF). * National Parks and Ecotourism; US$ 43.1 million (including several ICDPs - Integrated Conservation and Development Projects - already under implementation): In continuation of the work already developed under EP1, the objectives during the EP2 would be to: (i) complete the establishment of the network of protected areas (40 areas, 21 of which already well advanced under EP1); (ii) ensure proper conservation; (iii) promote ecotourism development; (iv) carry out applied research programs; (v) promote environmental awareness and strengthen environmental education. The network would be made of eleven National Parks or Integral National Reserves, and twenty nine other protected areas, for a total of 1.4 million hectares. ANGAP would progressively take over direct management of the network. This would require a change in the formal mandate of ANGAP. The ICDP approach would be progressively replaced by the generic regional support mechanisms presented below. * Marine and coastal environment; US$ 12.2 million: work would proceed in parallel at three levels: (i) national level: formulation of coastal zone management policies, legal framework and master plan; (ii) formulation of action plans at regional level; and (iii) design and implementation of management plans at local level, initially in the Nosy Be and Toliara areas. The activities would be coordinated by a steering committee (ECOMAR) and managed by a small unit within ONE. - 6 - * Urban Environment; (cost included in other components): the urban environment activities included in the program are presented here for clarity, but are actually included under other components described below. The activities would include: (i) the integration of environmental concerns into urban development policies, including the updating of the Urban Code; (ii) support to urban management activities by communities and local Governments. A Steering Committee would be established to pilot urban-related activities; its secretariat would be within ONE. Generic mechanisms at regional and local level to support regionalization of programming and local management of natural resources, through the following three components: * Support to Local Natural Resource management and Land tenure security; US$ 9.3 million: institutional support to local NR management would include setting-up the appropriate legal and regulatory framework, training environmental mediators, and capacity building of the land-tenure administration (Direction des Domaines). Transfer of methodology and procedures to direct sub-sector components would be through actual transfer of management right at the level of 100-200 village communities. * Support to regional programming and spatial analysis; US$ 4.3 million: support would be provided to EP2 Regional Programming Committees (RPCs), in the form of visiting experts and full-time secretariat, both for program management and for technical analytical work (e.g. watershed management, ecological corridors, urban environment problems). * Regional Fund for Environmental Management; US$ 9.3 million: such a fund would offer a mechanism to finance environment management activities on a demand-driven basis; sub-projects sponsored by local governments or private organizations would have to fall within the priorities of the RPCs, and to match pre-defined eligibility criteria. Some of the activities that were initially proposed as sub-sector components (i.e. watershed management, urban environment) would fall under the generic mechanism of the Fund. Strategic activities; US$ 10.0 million: would include two components: (i) formulation and transfer of environmental policies, strategies and instruments (sector policies, urban environment policy, transversal strategies such as prevention and mitigation of natural catastrophes, planning tools, economic instruments) and (ii) making environmental impact assessment operational by setting up environment units at the level of all sector ministries. Support activities; US$ 18.5 million: such activities would take the form of free-standing components only to the extent that they cannot be incorporated into the main components listed above; this set would include five components: research, communication-education-training, geographic instruments, environmental information system, and program coordination and management, including monitoring and evaluation. - 7 - 9. Program size, cost and financing. Significant adjustments to the scope of the program and to the size of some components were introduced as a result of the December 95 and April 96 multi-donor missions: the scale of the watershed management and of the forest management components was significantly reduced on the basis of less ambitious targets; the scope and cost of the urban component and of the proposal on prevention of natural catastrophes were cut down; most support activities were also scaled down; the marine component was broadened up, and Regional Fund was introduced. Total program cost is now estimated at US$ 180 million (including taxes and contingencies). Such a cost is comparable to the cost of EP1 (US$ 150 million, most of it net of taxes). The level of pledges made by the different donors who participated to the pre-appraisal missions is US$ 105-110 million, in addition to US$ 15.5 already financed. Assuming that Government would finance about US$ 35 million (5 million taxes, 8 million net-of-tax financing, and 22 million through tax exemption against external grants), the financing gap stands at US$ 20- million. Some of it would be covered by additional financing expected from some donors (e.g. Japan, Norway), and the rest by scaling down the program. The country's commitment to such a large program would need formal confirmation, in the form of a 'program-law'. The law would be presented to the Parliament during its Autumn 96 session. 10. Program Implementation. The first phase program worked primarily as a set of coordinated but independent projects. Under the second phase, program integration would leap forward through the consolidation and strengthening of the annual programming and budgeting process, as well as the consolidation of the monitoring system. On the other hand, there would be no attempt at this stage to consolidate disbursement or procurement procedure between donors. 11. Implementation will be carried out by the various line agencies that were set-up during the first phase. High level policy guidance will be entrusted to a National Environment Council, under the Presidency of the Republic. Policy level coordination will be the responsibility of an Interministerial Environment Committee, also under creation; the Commissary General for the Environment (CGE), within the Ministry in charge of the Environment (currently the Ministry of Agriculture) will chair the Committee on behalf of the Prime Minister. Operational level coordination will be carried out by ONE. There need to better define the border line between the EP2 and other programs as well as to seek synergy between such programs would be addressed through the regionalization of the annual programming process and the proposed Regional Fund. All the implementation arrangements, including monitoring and evaluation and the corresponding indicators, would be spelled out in an implementation manual, currently under preparation. The mission is satisfied with these arrangements, that incorporate the lessons of the first phase (see para 5. above). 12. Disbursements would be in line with project implementation practice, that is a set of eligible payments for particular goods and services, based on an annual programming and budgeting process that would be participatory and decentralized, and include systematic beneficiary assessment. Major procedures for program management will be spelled out in an Implementation Manual that will be reviewed during - 8 - negotiations and formally adopted as a condition for credit effectiveness. At field level, all activities would be managed with strong local participation. Monitoring systems are being put in place under EP1, including a consolidated 'dashboard' that would provide key indicators on the status of environmental resources and on the impact of the program; the systems are expected to be fully operational before the beginning of the EP2. 13. Supervision of program implementation. Program implementation would be supervised jointly by donors twice a year, one in spring focusing on implementation, and once in autumn focusing on programming for the following year. Under EP1, the full time presence of a staff member at the Resident Mission has proven to be a key factor in smooth program implementation. For the EP2, it is proposed to maintain a similar arrangement, with the difference that several local donor representatives (e.g. USAID, France) have expressed interest in participating to the financing. 14. Participatory approach to Program Processing. The process of formulating the second phase program is being carried out entirely by Malagasy agencies. The initial participatory process, during the period June-December 1994, resulted in the preparation of an identification report that was discussed at the December 94 meeting of the program's Steering Committee (COS: Comite d'Orientation et de Suivi). Detailed preparation work was completed in November 1995. It included participatory processes to set priorities in biodiversity management and erosion control. In addition, a beneficiary assessment has been carried out to evaluate the first-phase activities involving local populations (i.e. land titling, micro-projects for erosion control, integrated conservation and development operations), and the conclusions were used as an input into appraisal. A multi-donor pre-appraisal mission took place in June-July 1995, and full program appraisal took place end- November 1995, involving ten donors, four international NGOs and all Malagasy agencies, and a follow-up multi-donor mission took place in March-April 1996. Proposals for Bank and GEF participation to the Program were defined during the missions. The preparation documents have been updated by the Malagasy, and a multi-donor follow-up mission is scheduled for mid-June 1996. Strong emphasis is being put on participatory preparation and appraisal, integration of activities into one single program to ensure proper balance between components, and compatibility with the country's overall PIP. Full attention is also being given to the need for proper economic analysis and risk assessment, in line with the latest recommendations of OED and the Africa Region. 15. Rationale for IDA Involvement. The Country Assistance Strategy for Madagascar was discussed by the Executive Directors on July 12, 1994, and a progress report was discussed on April 18, 1996. The Bank Group's overarching objectives in Madagascar are to help the government promote private sector-export-led growth, attack poverty, improve natural resource management, build local capacity and improve project implementation. The proposed project is consistent with the country strategy and contributes to meeting most of the foregoing objectives. The Bank has played a leading role since 1987 in the formulation and implementation of the NEAP. Continued involvement is essential to - 9- sustain the Government's commitment to difficult and critical changes in its public investment program, including by promoting the transition from projects to programs, and to mobilize the support of other donors. The Bank has also a key role to play in helping the country to mobilize GEF financing in relation with the global nature of the benefits that are expected from improved biodiversity protection. Proposals for IDA and GEF financing were specified at the time of joint program appraisal. GEF funding would be focalized on some specific components, namely National Parks, Multi-purpose Forest Eco-systems Management, and Capacity Building for Support to regional programming and spatial analysis. IDA would act as the lender of last resort, with the appraisal and supervision process focusing on the program as a whole and the use of IDA resources being defined through the annual programming process on the basis of the coverage and availability of other donor financing. 16. Processing of the program within the Bank. Two multi-donor mission appraised the program in November-December 1995 and March-April 1996. Pre-mission departure meeting took place in November 95 and February 1996. The three key issues that were identified to be looked at during the preparation/appraisal process were: (i) institutional implementation capacity in relation to program scope and overall size; (ii) economic rationale and justification; and (iii) fiscal constraints and financial sustainability. Conclusions are presented in paragraphs 9/10/11, 19 and 17 respectively. It is now proposed to carry out a formal Bank appraisal mission as part of the multi-donor follow-up mission mentioned in para. 14, which is scheduled for mid-June 1996. Agreement on the overall financing plan and pre-negotiation of the IDA contribution to the financing of the program would take place in Madagascar as part of the same mission. Conditionalities would include (i) the finalization and formal adoption of the Program Implementation Manual and of the Manual of Procedures of the Regional Fund, and (ii) the official creation of the National Environment Council and the Interministerial Environment Committee (para. 10). 17. Program sustainability. The financial sustainability of protected areas is a major issue. In the long run, the combination of income from eco-tourism (entrance fees to parks, royalties on private activities that benefit from the existence of a park, etc.) with the revenue from capital investment (e.g. through a trust fund or foundation such as the one recently established in the country) should be sufficient to ensure such a viability. In the short to medium term, external financing will be required. Given the nature of ANGAP's activity, there is a clear case for applying some GEF funds to this part of the EP2. Financial sustainability of forestry operations would come from a decrease in the need for Government intervention together with an improvement in recovery of stumpage fees and other levies. 18. Program Objective Categories. Natural resources management. Poverty alleviation. Institution building. 19. Program Benefits. Long term sustainable growth of the country cannot be achieved in the absence of proper management of its natural resources, and the cost of inaction would be higher than the cost of the program. The program would combine concrete actions with short term - 10 - measurable benefits with long term undertakings (e.g. policies, education) to ensure sustainability. Direct beneficiaries would include communities affected by the soil conservation schemes and the development activities of the conservation projects (protected areas, forest management, coastal management). Most beneficiaries would be within the poorest segments of the population. Induced benefits would come from the introduction of improved environmental impact analysis and mitigation measures for public investment, as well as from private investments in ecotourism facilities and services that would be induced by the program. An economic analysis of the program is being finalized. Given the program approach and the fact that most field activities would be demand-driven, it is not possible to forecast the exact nature of the various interventions. Instead, several models have been developed that demonstrate that key activities (ANAE mini-projects, forest management and protected areas) can be economically justified under a fairly wide range of initial conditions. On the other hand, indirect benefits on reduced downstream siltation have not been quantified, and they are in most cases considered substantial, so that total return would be in fact higher. In addition, given Madagascar exceptional biodiversity, it is safe to state that global benefits much exceed the cost of the program, and that the issue is only one of cost-effectiveness and financial sustainability; this is discussed in para. 17. The implication is that the various agencies would need to closely monitor costs as well as to perform economic modeling on an on-going basis in order to ensure that their work results in the greatest possible impact. 20. Risks. There are strong interactions between environment degradation, population increase and economic stagnation, including the stagnation of agriculture, so that the impact of the environment program would be limited in the absence of significant progress on the other fronts. Madagascar's future can be seen within two extremes. First, with continued 'muddling through', the prognosis is devastating -- net capital inflows will shrink rapidly, import capacity will be impaired, GDP per capita will continue to fall and poverty will rise rapidly creating the real possibility of social explosion. The second scenario for Madagascar's future could materialize if the government can overcome internal differences and reticence toward comprehensive reform, and formulate and implement a transparent and credible economic reform program that would lead to a foreign investment rebound and lay the basis for export-led growth. Based on experience in other countries, adoption and maintenance of a credible reform program from 1996 onward could elicit major new flows of foreign investment by about 1999, with growth accelerating toward the levels of fast-growing developing economies within about a decade. 21. Policies that discriminate against agriculture have a direct impact on incentives for deforestation and shifting cultivation; more generally speaking, the incentive framework for agriculture development (e.g. rural infrastructure and access to markets, availability of social and financial services) determines land use intensification and thus has a direct influence on natural resources management practices; such issues are being addressed under the on-going structural adjustment dialogue as well as under various sector projects. Policies that discriminate against tourism development (e.g. visa regime, air transport monopoly) would also affect the program negatively, because ecotourism is a major - 11 - potential source of income from protected areas. Other risks are related to the potential political instability; in particular, policies that would affect the institutional set-up would compromise program implementation. Contact Point: Public Information Center The World Bank 1818 H Street N.W. Washington D.C. 20433 Telephone No.: (202)458-5454 Fax No.: (202)522-1500 Note: This is information on an evolving project. Certain components may not necessarily be included in the final project. - 12 -