INTEGRATED SAFEGUARDS DATASHEET APPRAISAL STAGE Report No.: 84359 I. Basic Information Date updated: January 24, 2014 1. Basic Project Data Project ID: P148881 Country: South Asia Additional Project ID (if any): P147957 Project Name: Bangladesh Trade and Transport Facilitation Studies RETF Task Team Leader: Diep Nguyen-van Houtte Estimated Appraisal Date: January 29, Estimated Approval Date: January 30, 2014 2014 Managing Unit: SASDT Lending Instrument: Investment Project Financing RETF (Small Grants) Sector: Transport (70%), Trade (30%) Theme: Regional Integration (25%), Trade (25%), Transport (50%) IBRD Amount (US$m.): 0.00 IDA Amount (US$m.): 0.00 GEF Amount (US$m.): 0.00 PCF Amount (US$m.): 0.00 Other financing amounts by source: RETF, DFID (US$ m) 4.999 Total (US$ m) 4.999 Environmental Category: A Simplified Processing: Simple [ X ] Repeater [ ] Is this project processed under OP 8.50 (Emergency Recovery) Yes [ ] No [ X ] or OP 8.00 (Rapid Response to Crises and Emergencies) 2. Project Objectives The development objective is to support analysis of institutional and management constraints related to trade and transport facilitation, and to support the preparation of potential investments to facilitate national and regional trade and transport for Government and Development Partner support. 3. Project Description This activity is linked to the Bank-Executed South Asia Eastern Corridor Programmatic Trade and Transport Facilitation TA (P147957), and is an essential component of the NLTA program. The goal of the program is to improve the regional transport network and logistics performance, and increase intra-regional trade and cooperation in the Eastern sub-region of Page 1 of 11 South Asia, comprising Nepal, Bangladesh, Bhutan, and selected states in India's Northeast region. Third-country trade and connectivity aspects with East Asia will also be supported. This Recipient-Executed Trust Funded (RETF) Project will fund the following studies. Technical assistance will be incorporated in the terms of references for the consultants conducting the studies as needed. 1. IWT Dredging: Strategic prioritization of IWT routes, and dredging feasibility and design study for prioritized IWT routes (US$2.7 million, Projected Completion Phase 1 December 2014, Phase 2 June 2015). 2. Improvement of Sea Ports: Feasibility and design study for Karnafuli Container Terminal (KCT) at Chittagong (US$0.6 million, Projected Completion December 2014). 3. Thegamukh LCS Development: Feasibility, design and safeguards studies for Thegamukh (and possibly other LCS/land ports) Land Customs Station (US$0.3 million, Projected Completion December 2014). 4. Chittagong Hill Tracts Connectivity: Feasibility study of route options to connect Thegamukh and Chittagong Port, including environmental and social screening and alternatives analysis, followed by detailed designs of selected option (US$.4 million, Projected Completion June 2015) 5. Environmental and Social Safeguards Studies: for proposed investments or related to studies in Components 1, 2, and 4 (US$.7 million)  Environmental and Social Safeguards Studies for studies/investments managed by Ministry of Shipping, i.e. Components 1 and 2 (safeguards studies for Component 3 will be done as part of the technical study).  Environmental and Social Safeguards Studies for studies/investments managed by LGED, i.e. Component 4 6. PMU Capacity Support (US$.299 million) 4. Project Location and salient physical characteristics relevant to the safeguard analysis Dredging of Inland Waterways and Development of River Ports BIWTA provided a priority list of 53 Inland Water Transport (IWT) routes for dredging, and requested assistance for acquisition of six amphibian dredgers, various support vessels, navigational aids and development of 22 river ports. The routes and ports cover a significant portion of Bangladesh’s inland water transport network. The total length of the requested dredging is 3,099km and estimated volume is 341.3 million m3. This is a large number of routes to be financed given that financing is limited. The project will therefore further prioritize the list of routes and ports based on an economic cost-benefit analysis of the full list, in consideration of cargo/traffic forecasts and costs associated with road transport alternatives. Detailed feasibility, design, hydrology/geomorphology, environmental and social safeguard studies, as well as preparation of performance-based dredging bid packages, will be carried out under the proposed project only for the routes on the shorter, highest- priority list. Karnaphuli Container Terminal Chittagong Port Authority has requested financing for the construction of a new Container Terminal called Karnaphuli Container Terminal (KCT) at Chittagong Port. Currently, the general cargo is handled on Berths 1 to 12 with 6-8 meters draft. These are more than 50 Page 2 of 11 years old, dilapidated, have outlived their economic life and need reconstruction. Chittagong Port Authority (CPA) is planning to convert four of these (jetties 9-12, adjacent to CCT for a total of 700 meters of berths) to KCT. The studies will include technical, engineering, financial, economic, environmental and social safeguards aspects including hydrological and morphological studies. The expected future physical works of KCT under study are listed below:  Old berths structure comprising RCC superstructure and piles, concrete pavements, quarry run base and compacted sub-base, will be dismantled and debris disposed of outside port limits.  For construction, raw materials (cement, steel, aggregate and sand) will be stored in the area.  Batch mixing plants, vibration hammers and other construction machinery will be operative within the premises.  Dredging will be done in front of berths and in the approach channel. The dredged material will be deposited on side banks of the river or at the nearby low land.  There is not expected to be additional land acquisition required. However, the present sheds will be dismantled and container yards with Rubber-Tire Gantry (RTGs) cranes will be set up. Transport Connectivity between Rangamati/Chittagong Port and Thegamukh There are multiple route options for connecting Chittagong Port and Thegamukh on the border with India (Mizoram state). Although four routes including a waterway were proposed by the Government of Bangladesh, six more alternative routes are also under consideration. The total of ten possible routes involve a combination of roads and inland waterways. Although “katcha� motorable roads are shown in the LGED map for the proposed route options, only a stretch of about 12 km in Bilachari was found to have Herring Bone Bond (HBB) roads with some old jeeps used as public transportation. According to local residents, the rest of the routes do not have any motorable roads in any form. People use waterway and foot trails to reach their settlements. Therefore, all potential road alignments will require major works including greenfield road construction. Route options including waterway stretches will involve dredging. All the routes will furthermore require numerous water crossings. Each route has pros and cons depending upon their purpose and use. The physical features of all the land routes are rolling hills with limited plains, full of vegetation with some forests. The soil geology is mostly silty clay with soft sand stone in some areas. Given the terrain and significant earth-moving required for road construction, landslides will be a risk. Kaptai Lake is a particularly ecologically sensitive area and will need careful treatment in the studies to ensure impacts to natural habitats and biodiversity are properly identified and mitigated. All of the routes furthermore pass through lands inhabited by tribal communities. Based on available information, the likely most efficient connectivity between Chittagong and Thegamukh is Chittagong-Ranguniya- Bangchara (Kaptai)-Chitmaran-Chakuwapara- Bhangamurapara-Bilaichhari-Silchhari-Mitingapara (Jurachhari)-Barkal-Chhotoharina- Thegamukh. However, a comprehensive screening and alternatives analysis will assess all potential options to identify the most optimal route, which will then be subject to further detailed studies including safeguards studies. Page 3 of 11 5. Environmental and Social Safeguards Specialists Leanne Farrell, Environmental Specialist, SASDI Iqbal Ahmed, Environmental Specialist, SASDI Akhtar Zaman, Social Development Specialist, SASDS 6. Safeguard Policies Triggered Safeguard Policies Yes No Environmental Assessment (OP/BP 4.01) X Natural Habitats (OP/BP 4.04) X Forests (OP/BP 4.36) X Pest Management (OP 4.09) X Physical Cultural Resources (OP/BP 4.11) X Indigenous Peoples (OP/BP 4.10) X Involuntary Resettlement (OP/BP 4.12) X Safety of Dams (OP/BP 4.37) X Projects on International Waterways (OP/BP 7.50) X Projects in Disputed Areas (OP/BP 7.60) X II. Key Safeguard Policy Issues and Their Management A. Summary of Key Safeguard Issues 1. Describe any safeguard issues and impacts associated with the proposed project. Identify and describe any potential large scale, significant and/or irreversible impacts. The feasibility and preliminary design studies under the project will lead to major investments in the Chittagong Hill Tracts (CHT) districts, Chittagong sea port, and along Inland Water Transport (IWT) routes and river ports across the country. The areas both north and south of Kaptai Lake of Rangamati (in CHT), at least one of which will likely be affected by the selected Chittagong-Rangamati-Thegamukh LCS transport connectivity route, are particularly sensitive from an environmental perspective, especially the areas of the Rampahar and Pablakhali Wildlife Sanctuaries. The CHT areas also have presence of tribal peoples in their ancestral territories with distinct culture, language and livelihood practices. These peoples will be socially impacted by the growth in transportation and commerce in that region. Although the studies to be conducted under this RETF project will not themselves generate any adverse environmental or social impacts, the future infrastructure investments which are the focus of these studies may have significant potential environmental and social impacts. Based on these considerations, the RETF is classified as Environmental Category "A". Classification of the TA as a Category A project will ensure that the environmental and social studies to be carried out through the project will meet Bank safeguards standards, such that any potential future World Bank investment project to finance any of the activities being studied under this project would require minimal if any additional preparation-stage environmental and social impact assessment work to ensure safeguards compliance. Full Page 4 of 11 environmental and social studies, and development of related environmental, social, resettlement and tribal peoples action plans, will thus be conducted in accordance with World Bank Safeguards and Government of Bangladesh policies as part of the proposed RETF. Impact assessment and management planning through the studies will ensure that future investments adequately avoid, minimize mitigate and/or compensate for all identified impacts. World Bank safeguard policy OP/BP 4.01 (Environmental Assessment) has been triggered to ensure that the studies focus on avoiding, reducing, mitigating and managing adverse impacts and enhancing positive environmental and social impacts of the potential future investments. Significant environmental issues associated with the future potential investments relate to dredging of prioritized IWT routes from among the 53 pre-identified routes; river and land ports development; reconstruction of Karnaphuli Container Terminal; and establishment of Chittagong-Rangamati-Thegamukh road connection. Natural Habitats (OP/BP 4.04), Pest Management (OP 4.09), Physical Cultural Resources (OP/BP 4.11) and Forests (OP/BP 4.36) have been triggered as precautionary measures; their applicability and necessary compliance actions under each will be verified in the course of execution of the various studies corresponding with each potential investment noted above. The environmental studies will also conform to requirements for EIAs and Environmental Clearance Certificates as per Bangladesh’s Environmental Policy (1992), Environment Conservation Act (1995), Environment Conservation Rules (1997), as well as other applicable requirements specified under the Wildlife Conservation (protection and safety) Act (2012) and Fisheries Policy (1998). The social safeguard policies -- Indigenous Peoples (OP/BP 4.10) and Involuntary Resettlement (OP/BP 4.12) -- have been triggered, given that some of the investments which are the focus of study are planned in areas where a significant number of tribal peoples1 live (e.g., CHT area), and at least some of the physical works associated with various proposed investments under study will require displacement of people and/or economic activities due to land acquisition. The future investment activities under study would involve acquisition of land which, in many cases, will result in displacement of people and economic activities. For the proposed Chittagong-Rangamati-Thegamukh connectivity route, displacement is likely to involve tribal peoples in the CHT areas. Governance and land management in the CHT area is different from the rest of the country, so lands to be acquired for the selected route in the CHT area will need to follow “The Chittagong Hill Tracts (Land Acquisition) Regulations, 1958�, whereas other proposed investments elsewhere in the country requiring land acquisition would follow the “The Acquisition and Requisition of Immovable Property Ordinance, 1982 (Ordinance II of 1982)�. In all cases, compliance with World Bank OP 4.12 on Involuntary Resettlement, as well as additional requirements related to land acquisition for tribal peoples as per OP 4.10 where required, will also be ensured for land acquisition and resettlement planning. With respect to the International Waterways policy (OP 7.50), the policy is triggered; however, since the proposed project is only financing preparatory studies, all sites for proposed investment are not yet known, and no investments will be financed under the project, the project falls under the exception to the notification requirement as per 1 Tribal peoples are tribes, minor races, ethnic sects and communities living in the Chittagong Hill Tracts and dispersed in other plain districts in Bangladesh. They are distinct indigenous cultural groups having customary cultural, economic, social, or political institutions separate from those of the mainstream society and culture. They have their own indigenous language different than the mainstream Bangla language. These small groups of peoples have similar characteristics of indigenous peoples covered under the World Bank OP 4.10. Page 5 of 11 paragraph 7 (a) of OP 7.50. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area. This project is only supporting technical assistance and studies, which will not have any direct environmental or social impacts. However, the future large scale investments arising out of these studies are likely to have significant impacts. The future investments overall are expected to improve economic prospects for local communities living along or near transit corridors and ports which are the target of the studies under this project. The Chittagong- Rangamati-Thegamukh LCS connectivity component will eventually lead to the most significant future impacts once developed, by opening up hitherto isolated areas in the Chittagong Hill Tracts to development and facilitating even better connectivity with India. This future investment, which the proposed project’s studies will help enable, will provide long term benefits to local communities and the country as a whole by helping to reduce trade and transport barriers in some remote upazillas (sub-districts) and between Bangladesh and India. However, the future unplanned developments which may arise in that area following development of the new road / inland waterway to Thegamukh may also increase stress on sensitive ecosystems and lead to tensions with tribal communities. Other future investments in dredging of inland waterways, upgrades and development of river ports, and development of the Karnaphuli Container Terminal at the Chittagong Port will also result in diverse long term positive and negative impacts associated with increased transport and port use. All of these impacts will be analyzed through the proposed environmental and social studies under this project. 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. The studies to be conducted in this project will explore all alternatives to avoid or minimize adverse impacts. The environmental and social assessments for each proposed intervention will be carried out in parallel to feasibility and design studies, so that environmental and social considerations can be factored into design decisions as they are being made. The studies will also cover the full range of anticipated impacts on relevant social and environmental receptors, including as applicable, historic and cultural heritage resources, protected areas, wildlife, sensitive and endangered species, bird migration and movement, rare plants, fisheries and aquatic environments, wetlands, vegetation, land use, human settlement (tribal communities and non-tribal settlers), air quality, climate, noise, landscape and visual environment, health and safety, etc. The goal of these studies will be to identify measures to avoid or minimize adverse impacts to the extent possible, while enhancing positive impacts. The social assessment will also investigate the social feasibility of investment options in terms of community engagement, land acquisition and population displacement, and adverse impact on tribal peoples. For the Chittagong-Rangamati- Thegamukh connectivity studies in particular, the initial feasibility analysis of the 10 potential routes will include environmental and social screening and alternatives analysis. Once the preferred routing and basic design option(s) have been established, full environmental and social assessment(s) will be carried out for the preferred option(s) in parallel with further economic, technical and design analyses. Page 6 of 11 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. Potential investments under study will be implemented by multiple agencies of GoB including Bangladesh Inland Water Transport Authority (BIWTA), Bangladesh Inland Water Transport Corporation (BIWTC), Chittagong Port Authority (CPA), Mongla Port Authority (MPA) and Bangladesh Land Port Authority (BLPA) under MoS, and Local Government Engineering Department (LGED) under the Ministry of Local Government, Rural Development and Cooperatives (MoLGRDC). The CHT Development Board (CHTDB) under the Ministry of Chittagong Hill Tracts Affairs (MoCHTA) will coordinate all relevant activities affecting CHT locations. However, the MoS and LGED will be contracting out the studies for preparation of the investments through this project, including safeguards related studies for the intended investments. While safeguards related work is indicated as a separate component of the proposed RETF (Component 5), the work will be conducted in parallel to activities under each of the other components, to ensure that relevant information for the assessments emerging from detailed feasibility and design studies are feeding into the impact assessment and management planning process, as well as to ensure that social and environmental aspects are being reflected back into decisions regarding route selection (in the case of the Chittagong- Rangamati-Thegamukh connectivity component) and design (for all other investments) so as to avoid or minimize negative impacts wherever possible. MoS and LGED will facilitate this coordination and ensure adequate information sharing across the consulting teams. An Environmental and Social Management Framework has been developed for the RETF to guide the approach to carrying out the safeguards studies. The Framework outlines additional detail on the process and required contents each of the specific safeguards studies required, as well as consultation and participation procedures, in order to ensure safeguard policy compliance for the various investments being planned under Components 1 to 4 of the project. For studies of investments in the CHT area, resettlement planning processes will take into account the unique governance and land management in that area, which is different from the rest of the country. Land acquisition in the CHT area will need to follow “The Chittagong Hill Tracts (Land Acquisition) Regulations, 1958�, while elsewhere would follow the “The Acquisition and Requisition of Immovable Property Ordinance, 1982 (Ordinance II of 1982)�. The ESIAs will also include review of project impacts and required mitigation and management measures in light of relevant national laws and policies, in addition to Bank safeguard policies and standards. The specific study approach for safeguards in relation to each component is outlined below. Component 1 (Strategic prioritization of IWT routes, and dredging feasibility and design study for prioritized IWT routes): The main environmental issues for this component relate to the impacts of dredging on aquatic environments, as well as selection and management of areas for disposal of dredged material on land. Among key social issues, displacement due to land acquisition for disposal of dredged material may be required. As the priority IWT routes are not yet selected, it is not yet known whether any will traverse areas where tribal peoples are present, but this is a Page 7 of 11 possibility. To ensure full identification and management planning for these and other relevant environmental and social impacts for the prioritized IWT routes once selected, a full Environmental and Social Impact Assessment (ESIA), Resettlement Action Plan (RAP), and Tribal Peoples’ Development Plan (TPDP) if required will be conducted in parallel with the detailed feasibility and design studies. The safeguards studies will be contracted out by MoS separately from the feasibility and design studies to an independent consultant, as required under OP 4.01 for Category “A� projects. Component 2 (Improvement of Sea Ports: Feasibility and design study for Karnafuli Container Terminal (KCT) at Chittagong): For this component, key safeguards issues relate to the Karnafuli Container Terminal construction, which will also involve dredging and rebuilding of a section of the existing Chittagong Port facilities. A full ESIA will be required for this proposed investment. While no new land acquisition is expected for the Container Terminal itself, the applicability of OP 4.12 (Involuntary Resettlement) will be confirmed during the detailed design stage (for example, in case lands are required for disposal of dredged materials). If needed, a RAP will be prepared. Component 3 (Thegamukh LCS Development: Feasibility, design and safeguards studies for Thegamukh (and possibly other LCS/land ports) Land Customs Station): This component will involve planning studies for the construction of a Land Customs Station (LCS) on a greenfield site in Thegamukh at the border with Mizoram state of India. Environmental and social impacts are expected to be minimal, site-specific, and easily mitigated or managed; nonetheless, an ESIA will be required to ensure adequate planning for impact management and to ensure local residents in Thegamukh are appropriately consulted. If required, a RAP and TPDP will also be carried out. In addition, if the borrower requests studies for other LCSs/land ports under this component, appropriate safeguards instruments will also be prepared as required for these additional facilities. The studies under this component will be contracted out by MoS. Component 4 (Chittagong Hill Tracts Connectivity: Feasibility study of route options to connect Thegamukh and Chittagong Port, followed by detailed designs of selected option): This component is the most sensitive from a safeguards perspective, given the social and environmental context of the CHT as well as the more broadly transformative nature of the new connectivity route to the region in terms of stimulating trade and facilitating market access to what is currently a largely isolated region. The safeguards compliance process will therefore consist of two steps: The feasibility study consultants contracted by LGED will design and conduct environmental and social screening for the full list of initial candidate routes under analysis, to inform the alternative site analysis and final selection of the preferred route for Chittagong-Thegamukh connectivity. This screening process will include, on the social side, a stakeholder analysis, community consultations and representative household surveys using Participatory Rural Appraisal (PRA) techniques, in order to produce a high level social and poverty baseline characterization of the 10 routes and to characterize key social impacts and associated with each alternative route’s development. On the environmental side, the screening should identify important environmental and social features at every 100m within a 150m buffer along each proposed route, as well as near possible locations of quarry and borrow sites, materials storage sites, construction camps and associated services (water supply sources and others), access roads, spoils disposal sites for wastes, dredge material disposal sites, and other Page 8 of 11 ancillary facilities associated with route construction. Appropriate locations for dredging and civil works, including river bed and floodplain locations, should be identified in consideration of social and environmental features and on the basis of feedback received during initial consultation events. There will be two outputs of the environmental and social screening process. First will be a comparative environmental and social scoping report, including for each route studied: (a) high level environmental, social and poverty baseline characterizations and stakeholder analyses, (b) identification of key likely environmental and social impacts and sensitivities (positive and negative) to be mitigated or enhanced, and (c) key safeguard policy as well as national legal compliance considerations. Where possible, the comparative analysis will highlight costs vs. benefits from an environmental and social perspective associated with development of the alternative routes. Once the preferred route is selected for further study, the second output will be a set of detailed draft TORs for the full ESIA, Resettlement Action Plan (RAP), and Tribal Peoples’ Development Plan (TPDP) to be completed for the selected route (see below). For the selected preferred connectivity route, a separate environmental and social consulting team will be contracted by LGED to carry out a detailed ESIA, RAP and TPDP for the preferred route, in parallel to detailed feasibility and design studies. The scope of the studies will also include the Thegamukh LCS and any additional land ports for which feasibility and design work is being done under Component 3 of the project. LGED will consult with relevant stakeholder groups on the TORs for the set of studies and make modifications as needed based on feedback received, prior to initiation of work by the independent consultants. The full studies will require additional baseline data collection, analysis, consultations with local communities (including free, prior and informed consultation with tribal communities who would be affected by future construction of the connectivity route), and development of detailed mitigation and management plans for all negative impacts. From an environmental perspective, key aspects of baseline assessment and impact analysis include: (a) flora and fauna including aquatic and terrestrial for the full area of influence; (b) landslide susceptibility in hilly areas, (c) impacts of cut and fill activities in hill and wetland areas respectively, (d) hydrology, sedimentation and siltation characteristics of Karnaphuli River and waterways to be dredged, (e) fish habitat and breeding areas, and (f) plan for dredging material disposal. Institutional capacity: MoS has not implemented any World Bank supported projects recently but LGED has long previous experience in implementing infrastructure projects under financing from the Bank and other donors. LGED therefore has existing knowledge of Bank requirements on environmental and social safeguards, community participation and gender empowerment. However, neither of these agencies has permanent resources for environmental assessment, social development and safeguards management. Other than the consultants’ services, additional professional resources with expertise in safeguards issues, including environmental and social assessment and management as well as land acquisition and involuntary resettlement planning, will be contracted by both MoS and LGED. Both of the agencies will contract an Environmental Specialist and Social Development Specialist for the study period to enhance their capacity in safeguards management and ensure quality planning acceptable to the Bank. The Bank team will also review all Terms of Reference, as well as draft and final versions of the technical studies, rigorously. Page 9 of 11 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. The investment project design will be inclusive of all social groups including women, vulnerable communities and tribal peoples. Public consultations (FGD/informal meetings) with all stakeholders will be carried out and the nature and number of consultation, location, and type of participants and the summary of findings will be documented. Consistent with requirements for Category A projects, the responsible agencies for each study (MoS and LGED) will hold consultations on the ESIAs outlined above at least twice – once prior to finalization of the TORs, and again once draft studies are available. In addition to national government agencies, key stakeholders to be consulted will include affected communities, traditional tribal organizations, NGOs, port and transport labor unions, etc. For studies related to potential investments in the CHT area which may affect tribal communities (e.g., Chittagong-Rangamati-Thegamukh connectivity route, inland waterway, and Thegamukh LCS port development as applicable), free, prior and informed consultation will be carried out with the tribal communities covering inter-generational groups. In addition to community-level consultations, GoB will also hold regular consultations with relevant agencies during study implementation. Particular attention will be given to the CHT area, which is politically, socially and environmentally-sensitive. In addition to formal administration of the government, these CHT districts have the existence of traditional administration under the tribal rajas (monarchs), who will be regularly consulted as the studies progress. Summaries of the sub-project specific ESIAs and related social safeguards (resettlement and tribal peoples) reports will be translated into local language and disclosed locally. Copies of the full reports (in English) and the summaries (in Bangla) will be sent to all applicable divisional / regional offices of MoS and LGED and will be made available to the public, both in hard copy and on the agencies’ websites. The English versions will also be disclosed in the World Bank InfoShop, once complete. The comments and the findings from the consultation workshops, along with any other feedback received from other interested persons and groups will be reviewed and incorporated in the final safeguards reports. B. Disclosure Requirements Disclosure Requirements Date Environmental and Social Management Framework Was the document disclosed prior to appraisal? yes Date of receipt by the Bank 1/22/2014 Date of "in-country" disclosure 1/30/2014 Date of submission to InfoShop 1/29/2014 Page 10 of 11 D. Approvals Signed and submitted by Name Date Task Team Leader Diep Nguyen-van Houtte January 16, 2014 Leanne Farrell and Environmental Specialist January 16, 2014 Iqbal Ahmed Social Development Specialist Akhtar Zaman January 16, 2014 Approved by: Regional Safeguards Coordinator Francis Fragano January 24, 2014 Comments: Sector Manager: Karla Gonzalez Carvajal January 16, 2014 Comments: Page 11 of 11