INTEGRATED SAFEGUARDS DATA SHEET APPRAISAL STAGE Report No.: ISDSA2349 Public Disclosure Copy Date ISDS Prepared/Updated: 07-Mar-2013 Date ISDS Approved/Disclosed: 07-Mar-2013 I. BASIC INFORMATION 1. Basic Project Data Country: Maldives Project ID: P131331 Project Name: Enhancing Education Development Project (P131331) Task Team Harsha Aturupane Leader: Estimated 07-Mar-2013 Estimated 30-Apr-2013 Appraisal Date: Board Date: Managing Unit: SASED Lending Specific Investment Loan Instrument: Sector: Secondary education (50%), Primary education (30%), Tertiary education (15%), Public administration- Education (5%) Theme: Education for all (50%), Education for the knowledge economy (50%) Financing (In USD Million) Total Project Cost: 11.00 Total Bank Financing: 10.00 Total Cofinancing: Financing Gap: 0.00 Public Disclosure Copy Financing Source Amount BORROWER/RECIPIENT 1.00 IDA Grant 10.00 Total 11.00 Environmental B - Partial Assessment Category: Is this a No Repeater project? 2. Project Objectives The project development objective is to enhance and strengthen strategic dimensions of education access and quality. 3. Project Description Component One: National Level Education Development (Total US$ 8.55 million: IDA US$ 7.95 million and GoM US$ 0.6 million) Page 1 of 11 1.1 National Assessments of Learning Outcomes for Policy and Program Development National assessments of learning outcomes have become one of the main vehicles for assessing Public Disclosure Copy education systems and formulating education policies in OECD countries and middle-income countries. The EEDP will support the Maldives to develop the capacity of the country to design and implement national assessments of learning outcomes in grades 4 and 7 according to a regular cycle for key subjects such as English, mathematics and Dhivehi, and use the results and findings for education policy and program development. The EEDP will help build the technical capacity within the MoE, especially the Education Supervision and Quality Improvement Division (ESQID) to undertake rigorous, state-of-the-art national assessments and to deliver short-courses, and in the National Institute of Education (NIE) to conduct advanced certificate or diploma level courses in national assessments of learning outcomes. The project will also build the capacity of selected policy makers and education specialists within the MoE, especially in the ESQID, the Policy Planning and Research Section (PPRS) and the NIE, to use the results and findings from national assessments for strategic policy and management decisions. The national assessments under the project will help monitor learning outcomes over time. The information and feedback from these national assessments can be used by policy makers and education specialists in key education areas such as curriculum development, pre-service teacher education, continuing teacher development, the production of educational material including textbooks, and the allocation of resources. 1.2 Management and Leadership Development of Staff in the Education Sector The EEDP will assist the MoE to develop the human resources in the education sector, with a special focus on education managers and administrators, school principals, and leading teachers who are potential future principals. The project will support a set of principals and leading teachers who already have bachelor’s degrees to obtain master’s degrees in education administration/management (either full time or in block mode). In addition, principals and leading teachers who only have diplomas will be supported to obtain bachelor’s degrees in a relevant field such as education management or administration. Priority would be given to the younger principals and leading Public Disclosure Copy teachers, to maximize the return on investment. The scholarships for Master’s and Bachelor’s degrees will cover expenses in the higher education institutions, such as tuition fees, and also other costs such as living expenses and transport. The scholarships for the programs would be administered by the Scholarships Section of the Department of Higher Education. This section has considerable experience of administering scholarships, since it handles government funded scholarships. The section also administered the scholarships under an earlier Bank funded education project, and has experience of Bank procedures. MoE staff, including from the Atoll Education Units, will be provided with short-term courses and/or exposure programs tailor made to develop their administrative, managerial and technical skills for work in the MoE and Atolls. This would cover in the Maldives Quality Assurance Authority (MQA), too. The short-term training would be administered by the Human Resources Division of the MoE. 1.3 Learning Environment Enrichment of Secondary Schools The Maldives has an atoll-wide network of schools that provide universal access to primary (grades 1-7) and secondary (grades 8-10) education. However, until recently access to higher secondary education (grades 11-12) was very limited, initially to one school in Male’, and then to four more schools in the atolls. The government has now adopted a policy to expand access to higher secondary education through about 38 strategically selected schools, across the country, which will serve as Page 2 of 11 hubs for higher secondary education in the atolls and in Male’. The higher secondary schools, and the secondary schools which feed students into them, need greater physical facilities and equipment, especially for IT and science. Strong IT skills are necessary for all secondary school completers who Public Disclosure Copy either plan to seek employment opportunities in the labor market or proceed onwards to higher education. Science subjects are needed to enable secondary school students to offer a curriculum options with subjects such as biology, chemistry and physics. Such subjects are pre-requisites needed for professions such as medicine, allied health sciences, engineering, electronics, and science teaching. These are professions which are in short supply among Maldivians, resulting in expensive expatriate staff being recruited for these occupations. The project will support a set of about 45 strategically selected schools, which include all 38 higher secondary schools and some of the large secondary feeder schools, to enrich their learning environments through the provision of IT and science equipment, and the expansion of classroom facilities in over-crowded large schools to help implement the government policy of single-session schools. This initiative is expected to help improve the transition rate from secondary to higher secondary education and increase the survival rate through the school system to grade 12. The additional facilities will also enable islands to conduct labor-market oriented skills training for youth, including after school hours as co-curricular activities. About 25,000 students, including all higher secondary students, attend these schools and will benefit from these facilities and equipment. The schools selected already have adequate numbers of teachers for these subjects, so that additional teachers will not be needed. However, the schools will receive support under the project’s activities for principal’s development, quality assurance and school-based teacher development. Hence, an integrated package of learning enrichment activities will be made available to these strategic higher secondary and secondary schools. Component Two: School Level Education Development (Total US$ 1.15 million: IDA US$ 1.0 million and GoM US$ 0.15 million) 2.1 School-Based Management Public Disclosure Copy The country has adopted a professional control model of school-based management, where the main decision-making authority has been devolved to principals and teachers. School-based management is a new initiative in the Maldives, and members of Senior Management Teams of schools and Schools Boards need training and capacity building in the aims and objectives of school-based management, the roles and responsibilities of the various school level agencies, and the variety of actions that can be taken under school-based management to improve the effectiveness and performance of schools. The EEDP will assist the MoE to train and strengthen the capacity of Senior Management Teams of schools and Schools Boards to take the school-based management initiative forward efficiently. Attention will be given to the fact that there are differences in abilities of principals, leading teachers, school boards and stakeholders, across the various atolls and islands, in the training and capacity building work. 2.2 Modernizing Quality Assurance for School Improvement Quality assurance (QA) is a key feature of education systems in many high income countries like Singapore, Scotland, the United Arab Emirates (UAE) and several middle-income countries including Malaysia and Sri Lanka. The MoE is keen to develop and establish a quality assurance system that encompasses internal self-assessments by schools themselves, consistent with international trends in Quality Assurance in OECD and middle-income countries. The EEDP will Page 3 of 11 help the MoE to establish a regular, annual QA system for schools, with the main emphasis on internal self-evaluations. The school self-evaluations (SSEs) would, in turn, feed into the School Improvement Plans for the following year. Public Disclosure Copy Larger schools would be trained and be able to conduct their own self-evaluations, and incorporate the findings and recommendations into improving quality in their schools. Smaller schools in remote atolls would receive training in self-evaluations too; however, they would also be supported to conduct self-evaluations and incorporate the findings and recommendations into their School Improvement Plans by atoll level education units, especially the Teacher Resource Centers. Privat e schools which receive government subsidies to enroll students would also be expected to be part of the QA program. The findings of the QA self-evaluations would also inform the school-based teacher professional development activities of schools. 2.3 Strengthening School-Based Professional Development (SBPD) for Teachers and Other School Staff The successful achievement of a high quality of education depends on the availability of an adequate stock of professionally educated, competent and motivated teachers. School-based teacher professional development has been noted globally for its effectiveness. The MoE is aware of the importance of school-based professional development (SBPD) for teachers as a promising strategy for continuing teacher education and training. The MoE has published a Professional Development Policy (PDP), developed SBPD guidelines for schools, and encouraged schools to conduct SBPD activities. It is mandatory for all academic staff in schools to receive a minimum of 15 hours (3 days) of professional development in every year. The SBPD guidelines seek to ensure that there is a procedure and process involved in the implementation of SBPD programs. The EEDP would assist the MoE, especially the NIE, to further develop the system for SBPD by improving the capacity of Professional Development (PD) coordinators and Teacher Resource Center (TRC) coordinators, helping schools undertake SBPD activities, and assisting the NIE to monitor the Public Disclosure Copy implementation of SBPD in schools. All schools in Male’ and the outer atolls would implement SBPD programs according to an annual cycle. The SBPD program would be related to and informed by the Quality Assurance self-evaluations by schools. 2.4 School Quality Assurance and Teacher Development Awards (QATDA) A system of School Quality Assurance and Teacher Development Awards (QATDA) would be supported under the project. The QATDA would assist school improvement activities through the implementation of School Improvement Plans and Annual School Feedback Forms (ASFF), with a special focus on quality assurance self-evaluations and school-based teacher professional development. Under the project all schools would receive an annual award of between MVR 6,000-7,500 (about US$ 400-500), depending on school size, commencing in 2014, to implement the findings and recommendation of the QA self-evaluations to improve student learning and soft skills, and to implement SBPD programs to enhance teacher performance. The QATDA will provide an incentive for schools to implement QA and SBPD activities. Under the QATDA, there would be an annual Memorandum of Understanding (MOU) between the MoE and schools to implement, monitor and report QATDA activities. The awards would be made available in the first year as an advance. In subsequent years, the awards would be made available on the basis of performance in the previous year on implementing QA activities and SBPD activities. Page 4 of 11 The implementation of the QA and SBPD activities would be monitored through the Annual School Feedback Forms (ASFFs). Public Disclosure Copy Component Three: Project Coordination, Monitoring and Evaluation, and Policy Analysis (Total US $ 1.30 million: IDA US$ 1.05 million and GoM US$0.25 million) 3.1 Education Strategy and Program Development The EEDP will support the government to develop future strategies and programs in priority areas through policy analysis and technical assistance. The GoM has identified the following priority areas for strategy and program development with support from the project: a) A Model for Multi-Grade Teaching in Small Schools The Maldives education authorities are considering multi-grade teaching given the geography of the country with its large number of small islands. Some of the schools in these islands have few students in each grade (as little as 3 students in some cases). Providing a teacher for every grade is very expensive. Multi-grade teaching would help reduce the exorbitant cost of providing education in these small schools. In addition, combining grades in such schools would potentially help enhance the cognitive and non-cognitive skills of students by giving them more opportunities for peer interaction. The EEDP will assist GoM with technical expertise to develop a framework for multi- grade teaching. b) A Model for Expanding Multiple Curriculum Streams in Secondary Schools The Maldivian education system contains three streams of study at the secondary level: arts, commerce and science. Due to resource constraints, most schools are unable to offer more than one stream of study in practice. At present, multiple streams of study are available in only a small subset of the 185 schools providing secondary education. In particular, very few schools offer subjects from Public Disclosure Copy the arts stream. As a result, a substantial proportion of students are compelled to study subjects within the confines of one stream, usually commerce, offered by their schools. Recognizing the need for a broader and more balanced curriculum, the government has been encouraging more schools to offer multiple streams of study at the secondary level. However, government policy makers and planners recognize that expanding course choices can be expensive, especially in schools where the science stream needs to be introduced. The EEDP will assist GoM with technical expertise to develop a framework for the expansion of multiple curriculum streams in schools that have sufficient numbers of students to make the broadening of choice feasible. c) Continuing (In-Service) Training for Untrained Teachers and for Inclusive Education The Maldives has about 3,600 teachers in primary education, of whom about 23 percent are untrained. The untrained teacher ratio is higher in the atolls than in Male’. One important reason for the relatively low learning outcomes and examination performances of Maldivian students is the poor quality of primary education, partly due to the substantial number of untrained primary teachers, in country. The MoE now recognizes that it is necessary to train the untrained teachers to bring them up to at least diploma level. The EEDP will support the MoE provide the necessary training programs for some of these untrained teachers so that they can reach at least the minimum of a diploma in education. Page 5 of 11 The MoE has adopted an Inclusive Education Policy to promote equity of education opportunities for children with special needs. The MoE started setting up classes for children with special needs in 2006, with a vision to develop a minimum of one school in each atoll that accommodates children Public Disclosure Copy with special needs by 2010. Currently 11 schools across the country (3 schools in Male’ and 8 schools in atolls) accommodate approximately 184 children with specials needs. The development of a framework of inclusive education will require training teachers in the pedagogical methods required for inclusive education. Some infrastructure and careful planning and establishment of its delivery mechanism is required. The EEDP will support the NIE to establish the delivery mechanism of inclusive education and provide a set of teachers with the training required for inclusive education. d) A Master Plan for Higher Education 35. The Higher Education Master Plan would provide the foundation for the future development of the higher education sector. The master plan would address issues such as the desired size and structure of the higher education sector, the governance of higher education, the roles of the public and private sectors, the quality of higher education, the economic and social relevance of higher education, and the costs and financing of the higher education sector. The project would support the development of the master plan through the technical assistance required, the consultation process, and the preparation and dissemination of the master plan. e) Strengthening the Maldives Qualifications Authority The EEDP would also help to strengthen the Maldives Qualifications Authority (MQA), which has the mandate to undertake quality assurance and accreditation of private and public higher education institutions. The EEDP would assist the Department of Higher Education (DHE) of the MoE and the MQA to develop the benchmarks, standards and review procedures for external quality reviews as well as guidelines for internal quality assurance units in higher education institutions. Also, the project would help the staff of the MQA involved in quality audits to obtain practical experience of undertaking reviews in another external QA agency. Public Disclosure Copy 4. Project location and salient physical characteristics relevant to the safeguard analysis (if known) Project will involve support to schools across Maldives. Certain outputs of the project will support the entire education system in the country and other outputs will be targeted towards selected number of schools. These targeted schools are yet to be identified and prioritized. Maldives is an island nation in the Indian Ocean formed by a double chain of twenty-six atolls oriented north-south off India's Lakshadweep Islands. The atolls of Maldives encompass a territory spread over roughly 90,000 square kilometres, making it one of the world's most geographically dispersed countries. Its population of 328,536 (2012) inhabits 200 of its 1,192 islands. Maldives' capital and largest city Malé had a population of 103,693 in 2006. The average ground level is 1.5 metres above sea level. The atolls are composed of live coral reefs and sand bars, situated atop a submarine ridge 960 kilometres long that rises abruptly from the depths of the Indian Ocean. The reefs are composed of coral debris and living coral. This acts as a natural barrier against the sea, forming lagoons. Other islands set at a distance and parallel to the reef, have their own protective fringe of reef. The islands are made of 15 cm thick layer of humus forms the top layer of soil. Below the humus Page 6 of 11 layer are 60 cm of sandstone, followed by sand and then fresh water. Due to high levels of salt in the soil near the beach, vegetation is limited there to a few plants such as shrubs, flowering plants, and small hedges. In the interior of the islands, more vegetation such as mangrove and banyan grow. Public Disclosure Copy Coconut palms, the national tree, are able to grow almost everywhere on the islands and are integral to the lifestyle of the population. The ground water of almost all inhabitant islands is polluted and the current supply of portable water is from rainwater harvesting and/or desalination of sea water. The temperature of Maldives ranges between 24°C and 33°C throughout the year. Although the humidity is relatively high, the constant cool sea breezes keep the air moving and the heat mitigated. The weather in Maldives is affected by the large landmass of South Asia to the north. The presence of this landmass causes differential heating of land and water. These factors set off a rush of moisture-rich air from the Indian Ocean over South Asia, resulting in the southwest monsoon. Two seasons dominate Maldives' weather: the dry season associated with the winter northeastern monsoon and the rainy season which brings strong winds and storms. The shift from the moist southwest monsoon to the dry northeast monsoon occurs during April and May. During this period, the northeast winds contribute to the formation of the northeast monsoon, which reaches Maldives in the beginning of June and lasts until the end of August. However, the weather patterns of Maldives do not always conform to the monsoon patterns of South Asia. The annual rainfall averages 254 cm in the north and 381 cm in the south 5. Environmental and Social Safeguards Specialists Mohamed Ghani Razaak (SASDS) Darshani De Silva (SASDI) 6. Safeguard Policies Triggered? Explanation (Optional) Environmental Assessment OP/ Yes Only school physical infrastructure design/ BP 4.01 planning, construction and operations and maintenance-related safeguards issues are Public Disclosure Copy anticipated through this project, which will be small in scale, temporary and can be managed through timely planning and adopting necessary mitigation measures. All physical activities will be conducted within existing school premises.It is proposed a project-specific Environmental and Social Assessment and Management Framework will be prepared to address the likely impacts associated with the project. Natural Habitats OP/BP 4.04 No Forests OP/BP 4.36 No Pest Management OP 4.09 No Physical Cultural Resources OP/ No BP 4.11 Page 7 of 11 Indigenous Peoples OP/BP 4.10 No There are also no indigenous peoples in Maldives and therefore this policy will also not be triggered. Public Disclosure Copy Involuntary Resettlement OP/BP No Maldives has unique land ownership structure 4.12 where all lands are under the Government ownership. Thus all Maldivians are entitled to shelter and as a result squatters are never found in public land or buildings. Within this context, the project will do not require triggering this Policy. Safety of Dams OP/BP 4.37 No Projects on International No Waterways OP/BP 7.50 Projects in Disputed Areas OP/BP No 7.60 II. Key Safeguard Policy Issues and Their Management A. Summary of Key Safeguard Issues 1. Describe any safeguard issues and impacts associated with the Restructured project. Identify and describe any potential large scale, significant and/or irreversible impacts: Environmental Impacts: The environmental impacts are expected to be limited to (i) the management of wastes at the rehabilitation /construction sites (waste water, solid waste, rejection and elimination of wastes such as oils and paints, demolished material), soil erosion, loss of vegetation, as well as dust and noise during the works; (ii) issues around the water supply, sanitation and solid waste management in the schools; (iii) high demand of material for construction, such as wood for furniture and windows, sand, etc.; (iv) structural integrity of the Public Disclosure Copy facilities; and (v) issues related to use and disposal of chemicals from laboratories. In addition to new construction activities, there may be rehabilitation activities related to water proofing of roofs, replacement of broken fittings, repairing malfunctioning drainage, water and electrical installations, painting, etc. that may give rise to environmental issues. The extraction of construction material particularly sand and coral aggregates could constitute a source of adverse impacts on the natural environment. Overall environmental impacts are expected to be temporary and of minimal if appropriate mitigation and management measures are adopted. Social Impacts: The anticipated social impacts during construction phase and operations phase once the buildings are in place are expected to be positive. This is considering the island communities urgent need for additional classrooms and other facilities to ensure better education system to their children. Multipurpose halls are expected to provide a venue for the island communities to hold function sand sports activities at an island and atoll level. Based on the consultations with the island communities there are no concerns with the likely increase in number of students from other islands and atolls. As it is, there are number students from other islands and atolls studying in the schools, which is an accepted practice in the Page 8 of 11 Maldives. Increase in students from other islands is seen as an indication of the high quality education that is provided by the school. Public Disclosure Copy Overall, the financial contribution to the implementation of Maldives education sector plan is likely to contribute positively to the social development of the country. As the project’s physical activities will be taken place on existing school premises and the possibility of encroachers residing within school buildings is very unlikely under the country conditions, there will not be any issues related to involuntary resettlement or livelihood impacts due to project activities. In addition, construction related impacts which have social implications have been already highlighted under the Environmental Impacts section above. Based on the above analysis, the project has been categorized as a Category B project and the project will trigger only OP/BP 4.01 – Environmental Assessment. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area: Since most of the outer islands, except Male will have limitations in large-scale development due to low economy of scale and limited space, there will be little or no indirect and/or long-term impacts due to anticipated future activities. All of the physical interventions will be undertaken on existing school premises on islands across Maldives. Construction activities are not anticipated to cause major environmental and social impact; hence no long-term environmental and social impacts are anticipated due to project activities except related to adequacy of facilities such as sanitation, water and waste management due to increase in the number of users within a given school, as well as adequacy of qualified teachers and incentives for teachers to continue. 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. Not applicable Public Disclosure Copy 4. Describe measures taken by the borrower to address safeguard policy issues. Provide an assessment of borrower capacity to plan and implement the measures described. The MoE has identified a list of schools requiring infrastructure development for the first 2 years of project implementation. Based on this list MOE has conducted an Environmental and Social Assessment including public consultation in all sites and prepared site-specific Environmental and Social Management Plans (ESMPs) for 8 schools. In addition, an Environmental and Social Management Framework (ESMF) has been developed for the project which provides guidelines for preparation of ESMPs to mitigate and manage potential impacts anticipated from activities to be undertaken under the project, particularly related to physical facilities. The ESMF is consistent with the World Bank safeguards requirements and GoM’s environmental regulations and associated requirements. The ESMF provides an environmental and environmental and social screening form, environmental, health and safety guidelines to ensure that adverse environmental and social impacts from project activities are identified and captured in the planning stages and contractor clauses to be used as part of contractual documents. The Information generated through the Environmental and Social Assessment and guidelines to follow during implementation have been consolidated into an Environment and Social Assessment and Management Framework (ESAMF) Although the likely impacts to the community will be mainly related to disturbance due to construction activities, a grievance redressal system has been proposed as part of the ESAMF, Page 9 of 11 which will be set up at the island level, as well as centrally at MOE to handle any issues arising during the project implementation. Public Disclosure Copy The MoE will be responsible for implementing the ESAMF, conducting the overall monitoring of the Project’s environmental and social safeguard activities and ensuring the proposed activities are in compliance with the ESAMF and investments are sustainable. Within this context, MoE will assign a staff member to be responsible for safeguards compliance of the project, including liaising with the World Bank safeguards specialist as needed. MoE will ensure that adequate capacity is available within the ministry or service is obtained from a suitable consultant to continue the safeguards screening of construction activities and preparation of ESMPs of proposed post 2014 construction works. MoE is also responsible to ensure adequate consultations are held as part of the screening process and such consultations are properly documented. MoE will provide adequate technical support to school authorizes on operations and maintenance of physical facilities. Monitoring of implementation progress of each construction will be carried out periodically by the MoE and World Bank. The MoE will monitor the project and submit monitoring and progress reports to the World Bank bi-annually. MoE will conduct necessary training to various groups involved in the implementation of safeguards requirements to ensure consistency in the application of environmental and social standards specified in the ESAMF. In addition, MOE has agreed with the Office of Operations and Program to take the lead in ensuring the safeguard requirements are including in bid documents and as engineer to the project, the safeguard compliance is maintained in all physical activities supported by the project. 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. As part of the ESAMF preparation extensive consultations were conducted at island-level specifically focused on the 8 islands selected to be supported during the first 2 years of the project. Consultations were held during the month of December 2012 with representatives from island/ atoll councils, school authority, representatives from parent-teacher association, representatives from community, non-governmental organizations and civil society organizations and their Public Disclosure Copy suggestions and concerns have been included into the ESAMF, as well as site-specific Environmental and Social Management Plans. The ESAMF has been disclosed in-country to public on February 21, 2013 and in the World Bank Infoshop on March 5, 2013. B. Disclosure Requirements Environmental Assessment/Audit/Management Plan/Other Date of receipt by the Bank 13-Feb-2013 Date of submission to InfoShop 05-Mar-2013 For category A projects, date of distributing the Executive Summary of the EA to the Executive Directors "In country" Disclosure Maldives 21-Feb-2013 Comments: 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: Page 10 of 11 C. Compliance Monitoring Indicators at the Corporate Level OP/BP/GP 4.01 - Environment Assessment Public Disclosure Copy 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? 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: Harsha Aturupane Public Disclosure Copy Approved By Regional Safeguards Name: Sanjay Srivastava (RSA) Date: 07-Mar-2013 Coordinator: Sector Manager: Name: Amit Dar (SM) Date: 26-Feb-2013 Page 11 of 11