INTEGRATED SAFEGUARDS DATA SHEET APPRAISAL STAGE Report No.: ISDSA9811 Public Disclosure Copy Date ISDS Prepared/Updated: 27-Jun-2014 Date ISDS Approved/Disclosed: 23-May-2014, 27-Jun-2014 I. BASIC INFORMATION 1. Basic Project Data Country: Jamaica Project ID: P147665 Project Name: Jamaica Foundations for Competitiveness and Growth (P147665) Task Team Thomas A. Vis Leader: Estimated 05-May-2014 Estimated 25-Jul-2014 Appraisal Date: Board Date: Managing Unit: LCSPF Lending Investment Project Financing Instrument: Sector(s): Public administration- Industry and trade (15%), SME Finance (30%), Agro- industry, marketing, and trade (15%), General industry and trade sector (40%) Theme(s): Regulation and competition policy (10%), Micro, Small and Medium Enterprise support (45%), Export development and competitiveness (4 5%) Is this project processed under OP 8.50 (Emergency Recovery) or OP No 8.00 (Rapid Response to Crises and Emergencies)? Public Disclosure Copy Financing (In USD Million) Total Project Cost: 50.00 Total Bank Financing: 50.00 Financing Gap: 0.00 Financing Source Amount Borrower 0.00 International Bank for Reconstruction and Development 50.00 Total 50.00 Environmental B - Partial Assessment Category: Is this a No Repeater project? 2. Project Development Objective(s) To strengthen the business environment in Jamaica for private sector investment. 3. Project Description Specific project components include: Page 1 of 11 Component 1: Enhancing competition in the business environment (US$ 3.1 million). This component will provide technical assistance (TA) and implementation support to address critical Public Disclosure Copy business regulation and procedural issues that constrain firm entry, operation and expansion, competition, and trade and logistics. Priority reform needs have been identified in collaboration with a wide range of public and private stakeholders, particularly JAMPRO in its role as Secretariat of the National Competitiveness Council (NCC) charged with overseeing the business reform agenda. The project will finance the following five priority activities, led by JAMPRO in coordination with relevant regulatory agencies: (a) TA to help streamline the development approvals and construction permitting process. The construction industry (together with real estate, renting, and related business activities) represents about 18% of GDP, but a key step in the process—application for a development approval—can take anywhere from eight to eighteen months, with the longest delays experienced by commercial projects. (b) Training and public outreach to increase the use of new institutions related to access to finance, specifically the moveable collateral registry and the credit information bureau. Further support will be provided to implement the recently tabled insolvency law, including outreach and training for insolvency professionals on the new legal framework. (c) TA to support regulatory reforms related to the legal framework for the Port Community System (PCS), a critical component of the LHI that provides an electronic single window to increase efficiency in port operations. (d) Legal and regulatory development for the new SEZ regime to replace the Export Free Zone regime being phased out per WTO compliance criteria, with a focus on including pro-competition regulatory elements to minimize market distortions. (e) TA to build the capacity of the Fair Trading Commission (FTC) to support its work proactively advocating for enhanced and fair competition in the economy. Component 2: Facilitating strategic private investments (US$ 17.6 million). This component will Public Disclosure Copy finance studies and TA to enable the government to prepare and close large strategic investment transactions with private sector participation. Strategic sectors include sectors such as agribusiness, energy, information and communications technology, logistics, transportation (airports, ports, etc.), social sector PPPs (such as health and education), tourism, and water and sanitation. DBJ will be the LCA for this component given its current responsibility for PPPs and privatizations within GOJ. Assistance provided through this component may be implemented in close coordination with the IFC to benefit from IFC’s PPP transaction expertise. Specific activities to be financed include: (a) Component 2A: Project preparation facility (PPF) (US$ 8.5 million). The PPF will finance studies and TA to facilitate strategic transactions such as infrastructure and social sector PPPs, divestments, and other strategic investments. Such studies and TA will include pre-feasibility, feasibility, financial, legal, environmental, and social as needed to bring strategic transactions to market. The criteria for selection of individual projects to benefit from a PPF-financed study and TA will include the potential to have a significant impact on growth and jobs and readiness for the transaction to be closed quickly. DBJ will work directly with MDAs that currently own and/or control infrastructure and other assets to bring private investment transactions to the market. Applications for studies and TA will be drafted by the MDAs themselves, with support provided by DBJ when requested. The applications will be submitted to the PPF Management Board (consisting of representatives of DBJ, PIOJ, JAMPRO, line ministries as appropriate, and members of two private sector organizations), which will recommend individual studies and TA for approval and funding to the overall Project Page 2 of 11 Steering Committee, with a no-objection required from the Bank. (b) Component 2B: TA and studies for investment support (US$ 9.1 million). The project will also Public Disclosure Copy finance TA and studies complementary to the PPF to increase GOJ capacity for strategic project origination, planning, and implementation, including: (i) Project origination and investment generation support for JAMPRO. This will include funding for investment facilitation of projects supported by the PPF, as well as support for project packaging for key private investment deals. (ii) Project pre-commissioning and contracting support, including funding three additional senior attorneys in the Attorney General’s Chambers to increase capacity to review key transaction documents and provide negotiation support. (iii) Contract management support to improve ex-post monitoring to ensure investors have delivered against contracts and investment plans. (iv) Financing for three critical sector planning studies: a Master Plan for the LHI with an industry analysis for SEZs, a redevelopment plan for downtown Kingston, and a tourism-agribusiness demand and linkages study. These studies will increase GOJ’s capacity to adequately prepare and implement investment and linkages plans for these sectors and development needs. PIOJ will be responsible for these stu dies given its overall coverage of policy and planning issues, with close technical collaboration with relevant ministries. Component 3: Supporting SME capabilities and finance (US$ 23.2 million). This component will provide support directly to SMEs by funding a combination of supply chain learning, skills upgrading, and finance. This component will be implemented by DBJ, with specific activities to include: (a) Component 3A: SME supply chain support and skills upgrading (US$ 7 million). The project will finance matching grants and TA to upgrade the capabilities of SMEs in specific eligible supply chains to meet the purchasing needs of large buyers. Eligible supply chains include all productive sectors that can generate high job multipliers from invested resources, such as agriculture and agro- Public Disclosure Copy processing, light and heavy manufacturing, and logistics services. A private contracting firm will be hired to manage the implementation of this sub-component. Specific activities to be financed include: (i) TA will be provided facilitate group problem-identification processes by applicant SMEs and a large buyer in a supply chain. An applicant group of firms will submit a proposal for skills upgrading needs, including a non-binding offtake agreement of potential increased purchases from SMEs by the large buyer, and identifying anticipated benefits such as new jobs created. This TA will help the firms produce a ‘supply chain business plan’, which will identify specific quality upgrading needs of individual firms and expected benefits along the supply chain. (ii) Based on acceptable supply chain business plans, the project will provide matching grants to individual firms to co-finance learning and skills upgrading to help SMEs meet the quality standards in the supply chain and increase sales to large buyers. A wide range of local providers of training services exists in Jamaica, and enabling flexible purchasing of relevant services is expected to spur local demand-driven supply. Co-financing will be provided by individual firms receiving the business development services, with a range of co-financing amounts depending on the size of firms with an emphasis on getting maximum participation in the program. (iii) The project will also finance TA to continue the initial group facilitation process as required, evolving into a public-private dialogue (PPD) mechanism to help resolve broader implementation bottlenecks such as specific regulatory and administrative barriers or the failure of existing public support schemes to reach intended beneficiaries. Page 3 of 11 (b) Component 3B: SME finance (US$ 16.175 million). The project will fund a line of credit (LOC) through DBJ for on-lending to approved financial institutions (AFIs) for loans to SMEs. Given ongoing tight liquidity in Jamaica, the LOC will provide critical access to finance for SMEs broadly, Public Disclosure Copy including for SMEs participating in the skills upgrading program. MOFP will absorb the exchange rate risk for ultimate repayment of this funding, enabling DBJ to on-lend in local currency and mitigate market liquidity constraints. AFIs may request funding for on-lending through two modalities: a) for individual credits to SMEs, or b) for a revolving credit line to fund eligible credits with ex-post review by DBJ, to facilitate the ease of on-lending. Banks will pay a commitment fee for the unused part of the revolving credit line (as funds can only be used once an eligible credit has been approved by the institution), and remaining balances can be canceled by DBJ in case the line is not used. These design aspects will stimulate use of funds under the LOC, although only the highest- rated banks in the financial system will be able to access the facility under this modality. (See Annexes 2 and 7 for additional details on the LOC and on financial markets in Jamaica.) Component 4: Project implementation and M&E (US$ 6.1 million), including: (a) Component 4A: Project management and implementation (US$ 4.5 million). This sub-component will fund all project management and operational costs associated with the project. These costs will include technical and fiduciary staff at PIOJ to establish a Project Execution Unit (PEU); technical coordination staff at DBJ and JAMPRO; and routine project audit and evaluation expenses. (b) Component 4B: TA for communications and productivity evaluation (US$ 1.6 million). The project will finance TA to support PIOJ’s implementation and evaluation of the project. Communications and outreach activities will be funded to generate public support for the project as well as for the overall productivity and growth agenda of GOJ. TA will be provided to PIOJ and the Jamaica Productivity Center (JPC) to conduct at least one evaluation study of the impact on SMEs of the skills upgrading and loans component, using elements of randomization to the extent possible. The project will also support the Statistical Institute of Jamaica (STATIN) to upgrade the quality of private sector data for broader GOJ impact evaluation and policy making by funding a national Public Disclosure Copy business census, which will enable proper subsequent annual sampling of firms to monitor productivity changes. 4. Project location and salient physical characteristics relevant to the safeguard analysis (if known) Component 1 of the project intends to improve the existing complex construction permitting process, which could indirectly affect environmental aspects if revisions/updates were to reduce the adequate consideration of potential environmental impacts in the permitting process. The potential risk for these environmental impacts is considered relatively limited. Component 2 includes prefeasibility, feasibility, sector planning, and other studies for infrastructure. The intent of this TA is to finance studies needed to bring large projects to commercial and financial close and to guide GOJ planning processes. The project will only finance studies, not actual investment project works. The potential risk is if these studies do not adequately address environmental impacts and risks. While some limited risk is present since these studies will be for projects with more significant potential impacts (i.e., large infrastructure), this risk is offset by the value-added of having these studies better incorporate environmental and social considerations, thereby enabling the Bank to support GOJ in integrating sustainability principles within sub-projects regardless of whether the construction is financed by the Bank. Page 4 of 11 Recognizing that there are a variety of study types with varying degrees of environmental implications, a three-tiered impact assessment approach will be adopted: Public Disclosure Copy In order to provide overarching guidance and a framework for future assessments, regional scoping and planning documents funded by the project such as the Master Plan for the LHI will include an identification of environmental and social assessment needs, definition of TOR elements for future assessments, and an estimation of costs to complete those studies for LHI-related projects (which may include airports, new manufacturing and warehouse facilities, aircraft repair facility, drydocks, container terminals, and a rail system). This high-level integrated approach to environmental and social assessment within the Master Plan will provide guidance, direction, and input for future more detailed assessments if and as they are subsequently proposed, whether or not such studies are funded by the Bank. The “second tier” of assessments that may be funded by the project would consist of in-depth Environmental and Social Impact Assessments (ESIAs) for specific potential investment transactions. ESIAs would be specified to include thorough analysis of regional and cumulative effects, social assessment needs, extensive consultation (including NEPA and in-country authorities), biological resource assessment, and other elements as identified in the scoping-level first-tier assessments. The second tier of assessments would be specified to comply with World Bank Performance Standards for Private Sector Activities and would provide due-diligence information consistent with Equator Principles to meet private investor needs. Specifically, “Performance Standards” means the Bank’s Performance Standard 1 (Assessment and Management of Environmental and Social Risks and Impacts) dated July 1, 2012, the Equator Principles Performance Standard 2 (Environmental and Social Assessment) dated June 4, 2013 and the associated performance standard in both documents determined to be applicable during the assessment process. The third and final tier of assessment would be directed towards in-country NEPA permitting and would essentially repackage the ESIAs to incorporate final technical details, and serve to pre-scope and streamline the final detailed design/permitting. This third tier could be funded with project loan Public Disclosure Copy financing as a near-final step in the project preparation process; or it could be conducted by the owners of infrastructure or other assets involved in the transaction process, but benefitting from any scoping document or second-tier assessments previously funded by the project. The benefit of this approach is that it will satisfy the need for an assessment of potential regional impacts in large planning studies funded by the project, but without including unnecessary details for future project elements which could substantially change or never materialize. It would also reduce reputational risk to the Bank by presenting an integrated approach at the early planning stages and providing guidance for future assessments to meet Bank policy and safeguards requirements. Finally, the adequate treatment of environmental aspects will reduce risk during technical assi stance related to project origination, commissioning and ex-post contract management. The Operational Manual will include requirements for ESIAs funded through the PPF to comply with the protocols set out in the regional planning and scoping studies, including World Bank Performance Standards for Private Sector Activities and Equator Principles standards with public consultation, cumulative impact assessment, and incorporation of relevant environmental policies and legislation of the Government of Jamaica. In this way, any environmental and social concerns of offshore investors will be addressed proactively, in a manner supportive of NEPA protocol, in a comprehensive and transparent fashion, and significantly advancing project preparation and permitting time. Page 5 of 11 Component 3 will provide loans to SMEs. The projects carried out by SMEs that receive financing for working capital or specific project investments could have negative environmental impacts. The Public Disclosure Copy SMEs eligible will include a range of sectors, but there is some desired focus on agroindustries, ICT, and logistics, and could be located anywhere in Jamaica. On average these are credits are expected to be in the US$ 100,000 to 300,000 range to SMEs (defined as less than 1.5 million USD gross income per year), and thus there is a low potential for sub-project investments to have moderate or high potential significant impacts. The types of SME activities could include tourism, agroprocessing, agricultural production, energy, manufacturing, warehousing, IT, or services. To address potential impacts from Component 3 activities, DBJ will use an Environmental Policy and Management System (EPMS) to screen applications, determine whether additional environmental investigation is required, and document the appraisals, as well as summarize and report the results in these risk management activities. DBJ developed an EPMS in 2011 for another World Bank-funded project (Energy Security and Efficiency Enhancement), and DBJ has updated and reissued this internal guidance document, which has been included in the EPMS for this project. AFIs who receive a line-of-credit will be required to adhere to the standards and protocols of DBJ’s EPMS at a minimum. Initial screening against an exclusion and referral list is first performed, using information provided in the credit application. Projects classified as Category A under World Bank OP/BP 4.01 are not eligible for financing under Component 3, as well as those on the IFC Exclusion List. The screening checklist further identifies those projects for which no further environmental investigation is required, and those for which the application process requires additional investigation. The checklist requires that the applicant provide information pertaining to local (Parish) permits and national (NEPA) permits; further, DBJ requires that all applicable permits be obtained prior to disbursement. If further environmental and social investigation is required, then DBJ will assign an Investment Officer and conduct a site visit. Roughly 40% of DBJ’s portfolio of over 1,000 loans has included such site visits as part of the application process, often conducted jointly with AFIs. The inclusion of Public Disclosure Copy expanded evaluations of environmental and social aspects will be conducted by staff of the Strategic Services section of the Bank (who will also support the financing of studies under Component 2). Environmental and social investigation may be cursory or detailed as required, and the results and evaluation of risk will be summarized in the credit documentation. DBJ will perform monitoring and reporting through annual reports to include the nature of the loans, environmental and social screening and risk evaluations, and a summary of the portfolio’s performance with respect to environmental and social aspects. SMEs will be obliged to comply with relevant environmental and social requirements as established in their sub-loan agreements, per the Operational Manual. DBJ requires that all projects must comply with relevant GOJ policies as required by the National Environment and Planning Agency (NEPA), which include permits and/or environmental and social impact assessments whenever appropriate. DBJ will require that AFIs adhere at a minimum to the environmental and social management standards as detailed in the EPMS for screening, appraisal, and reporting. The EPMS and the associated environmental and social requirements will be included in the project Operational Manual. Component 4 includes capacity building and technical assistance by World Bank. PIOJ will have a qualified environmental consultant on retainer to assist with the PPF relative to evaluation of TORs for ESIAs on large infrastructure projects. The existing DBJ system will be adapted and improved through World Bank supervision, training support and capacity building, including the addition of an Page 6 of 11 environmental and social risk management specialist in the Strategic Services section of DBJ. The World Bank environmental safeguard specialists will provide periodic supervision and training Public Disclosure Copy relative to the identification and management of environmental risk in project evaluation and implementation. The World Bank will assist DBJ to identify appropriate external training opportunities for environmental screening and environmental management for AFI project officers, field supervision staff, small and medium enterprise development officers and selected community representatives to familiarize them with the principles and procedures. Permitting through NEPA will be checked as part of all supervision and monitoring actions. A permit or license may be suspended or revoked if any of its terms or conditions is breached, or if the holder fails to submit any documents and information as NEPA may require. The undertaking of a prescribed activity without the holding of an appropriate Permit will bring substantial penalties, on conviction in a court of law. Environmental monitoring reports may be required by NEPA as a condition of an Environmental Permit. In such cases, the Bank will also review these reports during the periodic supervision missions. Regarding consultation, the draft EMF for the project was disclosed for public consultation by PIOJ prior to appraisal, a public consultation was held subsequently with key stakeholders, and the final EMF will be disclosed on the World Bank website. Continued consultation of future projects would occur through ESIAs compliant with Equator Principles and World Bank Performance Standards for Private Sector Activities and using in-country systems through NEPA for projects under the PPF (Component 2). The Master Plan for the LHI will lay out public consultation elements for high- visibility large infrastructure projects to encourage transparency and broad stakeholder engagement, and will define the consultation plan for environmental and social aspects. 5. Environmental and Social Safeguards Specialists Jose Vicente Zevallos (LCSSO) Public Disclosure Copy Michael J. Darr (LCSEN) 6. Safeguard Policies Triggered? Explanation (Optional) Environmental Assessment OP/ Yes Component 2 (PPF-related) studies will have no BP 4.01 direct environmental impacts, but future investments associated with project activities may have indirect environmental implications; and, Component 3 (SME-related) may fund activities with direct impacts. Accordingly, OP/BP4.01 is triggered and a three-tiered assessment strategy will be adopted. First, for major studies such the Master Plan for the Logistics Hub Initiative (LHI), the Downtown Kingston Revitalization Plan, or privatization of government assets in the tourism industry, scoping-level assessments would be included within each study to guide TORs for future ESIAs (second tier) which will comply with World Bank Performance Standards for Private Sector Activities and Equator Principles, including assessment of cumulative Page 7 of 11 impact and public consultation requirements. The third tier of assessments would be EIAs subsequently modified and finalized for in- Public Disclosure Copy country permitting through the environmental policies and legislation of the Government of Jamaica, and would be facilitated by the previous studies but not funded directly by the Bank. Financing of SMEs will include agricultural processing, manufacturing, tourism and other activities with environmental implications; therefore, DBJ will employ an Environmental Policy and Management System, which has been adapted and improved for the types of projects under consideration, and will require AFIs to conduct screening, appraisal and reporting. To capture these environmental management elements, an Environmental Management Framework (EMF) has been prepared. The draft EMF was publicly disclosed prior to appraisal, and a consultation was subsequently held with key stakeholders to receive comments. A final EMF including any comments received will be disclosed on the World Bank website. Natural Habitats OP/BP 4.04 No This policy is not triggered, as the project will not finance activities that have a direct impact on natural habitats. As part of the EMF, all environmental analysis conducted related to studies to support subsequent private investment Public Disclosure Copy activities (PPF-related orSME-related) will exclude those with any significantly potential impacts on natural habitats. Forests OP/BP 4.36 No This policy is not triggered, as the project will not finance activities that have a direct impact on the management of forests or forest-dependent communities. As part of the EMF, all environmental analysis conducted related to studies to support subsequent private investment activities will exclude those with significantly potential impacts of the investments on forests. Pest Management OP 4.09 No This policy is not triggered, as the EMF will include provisions regarding the procurement or use of pesticides. All EIAs conducted related to studies to support subsequent private investment activities, and the environmental considerations regarding loans to SMEs, will adhere to requirements in the EMF regarding the investments to purchase or use pesticides. Page 8 of 11 Physical Cultural Resources OP/ No This policy is not triggered, as the project will not BP 4.11 finance activities that have a direct impact on physical cultural resources. All environmental Public Disclosure Copy analysis conducted related to studies to support subsequent private investment activities will consider the potential impacts of the investments on physical cultural resources as appropriate, including chance finds procedures as described in the EMF. Indigenous Peoples OP/BP 4.10 No This policy is not triggered, as there are no indigenous peoples as defined under OP 4.10 in Jamaica. Involuntary Resettlement OP/BP No This policy is not triggered, as the project will not 4.12 finance activities that will directly cause involuntary resettlement or require land acquisition. All social analysis conducted related to studies to support subsequent private investment activities will consider the potential need for land acquisition associated with the investments, as well as the situation of land ownership and occupation. Safety of Dams OP/BP 4.37 No This policy is not triggered, as the EMF will exclude any project related to large or high hazard dams. Projects on International No This policy is not triggered, as the project will not Waterways OP/BP 7.50 finance activities that have a direct impact on international waterways. All analysis conducted Public Disclosure Copy related to studies to support subsequent private investment activities will consider the potential impacts of theinvestments on international waterways as appropriate. Projects in Disputed Areas OP/BP No This policy is not triggered, as the project will not 7.60 finance any activities in disputed areas as defined under the policy. 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: Component 2 (the PPF) would fund ESIA studies for large projects, which would be scoped first in the LHI Master Plan and Downtown Kingston Redevelopment Plan and subsequently prepared in accordance with World Bank Performance Standards for Private Sector Activities and Equator Principles; final permitting through in-country systems (facilitated but not funded by the Bank) would also require EIAs for any major projects. Potential impacts from Component 3 (related to SME lending) would be minor and manageable through DBJ screening, appraisal, and reporting as well as use of in-country systems for local and national permitting. Page 9 of 11 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area: There are no anticipated direct long-term impacts which could be attributed to the project. Public Disclosure Copy Potential indirect impacts of the project would be addressed through scoping and ESIAs funded by Component 2 (the PPF), including regional scale and cumulative impacts in accordance with WBG standards. Any direct impacts of small projects by SMEs would be addressed through the DBJ Environmental Policy and Management System. 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. It is possible that alternatives exist to some of the major interventions being studied (e.g. the LHI). Alternative analysis would be considered in the context of preliminary scoping (through Master Plan preparation) and direct funding of any ESIAs for those activities. 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. An EMF has been prepared which includes separate environmental management elements for Component 2 (PPE-related) and Component 3 (SME-related) activities. For PPF-related activities (Component 2), the PIOJ will ensure that adequate consideration of environmental aspects is included in all TORs. This shall include, for example in feasibility studies, the adequate consideration of environmental and social aspects (impacts, risks and benefits) as part of any alternative analysis, public participation in the preparation of the study as relevant, and specific conclusions and recommendations regarding environmental management for the project development and implementation. The TOR for any ESIA or similar study shall require that such study comply with (1) all applicable Jamaica environmental regulatory requirements and (2) World Bank Performance Standards for Private Sector Activities and any applicable requirements in Equator Principles. The PIOJ plans to have a qualified environmental specialist on retainer to manage environmental aspects of the PPF including TOR development, ESIA review, and ex-post contract management. For SME-related activities (Component 3), screening and management Public Disclosure Copy would use the DBJ Environmental Policy and Management System included in the EMF, which was adapted from a previous DBJ project. DBJ plans to staff an environmental specialist to support its SME portfolio. 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. The EMF for the project was disclosed for public consultation prior to appraisal, a consultation was subsequently held with key stakeholders, and the final EMF will be disclosed via the World Bank website. Additional disclosure and consultation regarding future Component 2 projects would occur, as applicable, through ESIAs conducted following World Bank Performance Standards for Private Sector Activities, as well as EIAs conducted by others for NEPA permitting. B. Disclosure Requirements Environmental Assessment/Audit/Management Plan/Other Date of receipt by the Bank 10-Apr-2014 Date of submission to InfoShop 27-Jun-2014 For category A projects, date of distributing the Executive Summary of the EA to the Executive Directors Page 10 of 11 "In country" Disclosure Jamaica 14-May-2014 Comments: The Environmental Management Framework (EMF) was disclosed in country by Public Disclosure Copy PIOJ via website announcement, announcing that public comments are welcome. A follow-up consultation was held in country with stakeholders to receive comments on the EMF. If the project triggers the Pest Management and/or Physical Cultural Resources policies, the respective issues are to be addressed and disclosed as part of the Environmental Assessment/ Audit/or EMP. If in-country disclosure of any of the above documents is not expected, please explain why: C. Compliance Monitoring Indicators at the Corporate Level OP/BP/GP 4.01 - Environment Assessment Does the project require a stand-alone EA (including EMP) Yes [ ] No [ ] NA [ ] report? If yes, then did the Regional Environment Unit or Sector Yes [ ] No [ ] NA [ ] Manager (SM) review and approve the EA report? Are the cost and the accountabilities for the EMP incorporated Yes [ ] No [ ] NA [ ] in the credit/loan? 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? Public Disclosure Copy 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? 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: Name: Thomas A. Vis Approved By Sector Manager: Name: Subrahmanya Pulle Srinivas (SM) Date: 27-Jun-2014 Page 11 of 11