INTEGRATED SAFEGUARDS DATA SHEET APPRAISAL STAGE Report No.: ISDSA1617 Public Disclosure Copy Date ISDS Prepared/Updated: 04-Apr-2014 Date ISDS Approved/Disclosed: 07-Apr-2014 I. BASIC INFORMATION 1. Basic Project Data Country: OECS Countries Project ID: P127226 Project Name: Saint Lucia Disaster Vulnerability Reduction Project (P127226) Task Team Tiguist Fisseha Leader: Estimated 24-Mar-2014 Estimated 14-May-2014 Appraisal Date: Board Date: Managing Unit: LCSDU Lending Investment Project Financing Instrument: Sector(s): Public administration- Water, sanitation and flood protection (20%), Other social services (5%), Rural and Inter-Urban Roads and Hig hways (25%), Flood protection (50%) Theme(s): Natural disaster management (50%), Climate change (50%) 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: 68.00 Total Bank Financing: 41.00 Financing Gap: 0.00 Financing Source Amount BORROWER/RECIPIENT 0.00 International Bank for Reconstruction and Development 0.00 International Development Association (IDA) 41.00 Strategic Climate Fund Credit 15.00 Strategic Climate Fund Grant 12.00 Total 68.00 Environmental B - Partial Assessment Category: Is this a No Repeater project? 2. Project Development Objective(s) Page 1 of 11 The Project Development Objective (PDO) is to reduce vulnerability to natural hazards and climate change impacts in Saint Lucia. 3. Project Description Public Disclosure Copy The Project comprises the following five components: Component 1 – Risk Reduction and Adaptation Measures (US$51.4 million). This component would support structural and non-structural flood and landslide risk reduction interventions and climate adaptation measures to improve Saint Lucia’s resilience against current and future climatic shocks. Additionally, the component would finance the reconstruction of critical infrastructure damaged during the December 2013 flooding, using the ‘build back better’ approach. Activities under this component will also account for other potential risks (e.g. seismic) to ensure financed works are generally disaster resilient. Sub-projects include the following: (i) reinforcement of flood control infrastructure, including at the international airport; (ii) climate resilient rehabilitation of road sections along the national highway through drainage improvements, slope stabilization works and retrofit of select bridges; (iii) retrofits and climate resilient rehabilitation of priority emergency shelters; (iv) climate-resilient rehabilitation of deteriorating water supply infrastructure; and (v) retrofit and rehabilitation of existing schools and health centers. Additionally, relevant national plans, policies and strategies to support risk reduction and climate resilience efforts would be developed, including, inter alia: a national watershed management framework, a rainwater harvesting pilot program, and a climate change public awareness and education strategy. Importantly, technical assistance and capacity building are embedded within sub-activities and include: (i) development of operation and maintenance plans, including a bridge maintenance plan, (ii) risk assessments to support engineering design options and final detailed design solutions, and (iii) integrated hazard and climate analyses to inform project designs. Component 2 – Technical Assistance for Improved Assessment and Application of Disaster and Climate Risk Information in Decision-Making (US$7.6 million). This component would support Public Disclosure Copy capacity building for open systems and platforms to create, share, analyze and use disaster risk and climate change data and information for improved decision making and engineering design for risk reduction and climate change adaptation. Specifically, the component would finance, inter alia: (i) the creation of a high resolution digital topographic and bathymetric model for Saint Lucia, (ii) sea level rise modelling and coastal flood and erosion risk mapping; (iii) design and deployment of meteorological, hydrological, and sea level rise monitoring networks to provide high resolution hydrologic data; and (iv) deployment of an environmental health surveillance system. Data collected under this component would be used to inform investments under Component 1 (when suitable) as well as to identify and prioritize future risk reduction and adaptation investments. Data outputs would also inform the development of appropriate land use plans and provide a basis for future flood and landslide risk management schemes. Component 3 – Climate Adaptation Financing Facility (CAFF) (US$5.0 million). This component is designed to pilot a financing mechanism meant to incentivize pre-emptive climate adaptation amongst Saint Lucian households and businesses. Loans would be offered to finance works and activities which build the resilience of assets and livelihoods to adverse hydro-meteorological events. Saint Lucia Development Bank (SLDB) would serve as retail bank and on-lend to final beneficiaries – with a concerted aim of building an affordable and self-sustaining loan portfolio in climate adaptation. Based upon the initial success of the component and local demand for climate adaptation Page 2 of 11 loans, consideration will be given to include other commercial banks as participating retail banks. SLDB would receive technical assistance to address identified gaps in its current operation and risk Public Disclosure Copy management structure and practices. A standalone OM would be generated for the CAFF, while SLDB would receive systematic support in implementing an institutional development plan to overcome existing gaps, and would monitor progress to this end. Component 4 – Contingent Emergency Response (US$1.0 million). This provisional component would allow rapid re-categorization and reallocation of project financing from other project components to partially cover emergency response and recovery costs associated with a natural catastrophe. The component would only be triggered upon formal declaration of an emergency by GoSL, in accordance with the Saint Lucia Constitution Order 1978, following the occurrence of a disaster. This component could also be used to channel additional disaster response funds should they become available. A specific OM would apply to this component, detailing financial management, procurement, safeguards and any other necessary implementation arrangements. Component 5 – Project Management and Implementation Support (US$3.0 million). This component would finance activities required for efficient project management and implementation through the provision of technical advisory services, staffing, training, operating costs and acquisition of goods. The component would also cover incremental operating costs, including those related to operating the Project Coordination Unit (PCU) under the Ministry of Finance, Economic Affairs, Planning and Social Security (MoF) and the Sustainable Development and Environment Division (SDED) of the Ministry of Public Service, Sustainable Development, Energy, Science and Technology (MoSDEST). Incremental operating costs incurred by implementing agencies would also be covered as well as those required for outside consultancies to prepare and supervise specific activities, technical audits, and M&E. 4. Project location and salient physical characteristics relevant to the safeguard analysis (if known) Public Disclosure Copy Project works would be carried out throughout Saint Lucia. Works will include, but are not limited to (a) the repair and rehabilitation of existing infrastructure, (b) new construction of select public facilities, (c) erosion control works and new construction of river defense structures to protect human settlements and critical infrastructures (including the international airport), and (d) community-based small mitigation works (e.g. slope stabilization, community drainage systems). Certain project activities (including riverbank reconstruction and slope stabilization) would entail relatively minor construction works with some potential environmental impacts. And as Saint Lucia has a number of designated Forest Reserves, the possibility exists that works will occur in such areas, thereby having implications for the Natural Habitat policy. Saint Lucia shares similar disaster vulnerabilities with other OECS countries, which include volcanic eruptions, seismic activity, sea level rise as well as variability in rainfall and storm intensity related to climate change. Like Saint Lucia, the small island developing states of Dominica, Grenada and Saint Vincent and the Grenadines share common hazard profiles for flooding, landslides, storm surge and coastal erosion, which are addressed in the corresponding national disaster vulnerability and climate risk reduction programs. Similar lessons learned are expected to be generated from comparable hydro-meteorological monitoring and watershed management practices, construction techniques as well as contractor logistics, which will be shared and applied across all related projects throughout the four island states. Environmental management practices common to the sub-region Page 3 of 11 will also be evaluated and incorporated into safeguards analysis and instruments in the Saint Lucia project. 5. Environmental and Social Safeguards Specialists Public Disclosure Copy M. Yaa Pokua Afriyie Oppong (LCSSO) Michael J. Darr (LCSEN) 6. Safeguard Policies Triggered? Explanation (Optional) Environmental Assessment OP/ Yes An Environmental Assessment (EA) as well as an BP 4.01 environmental safeguards instrument (Environmental Management Framework – EMF) have been prepared by an external consultant, to preliminarily assess potential subprojects and to present appropriate screening methods and procedures for the application of Bank safeguards, including guidance on the scope of studies required to complete for each subproject as well as criteria for triggering additional studies in the case of complex or significant activities (e. g, construction of the Dennery Polyclinic health facility, and possible work in forest areas and along sensitive coastlines). A generic Environmental Management Plan (EMP) will be used in simple situations where activities need no additional assessment. The studies and management plans related to each subproject should be completed prior to commencement of any work. The majority of works will likely be Public Disclosure Copy small-scale and simple in nature with environmental impacts limited to the construction phase, requiring only the application of the standardized and generic EMP. Any exceptions will be identified during the screening phase (as detailed in the EMF) and additional assessment work will be done during project implementation, if required. Natural Habitats OP/BP 4.04 Yes OP/BP 4.04 has been triggered as a precaution to ensure the development and inclusion of clear screening criteria related to natural habitats within the EMF. Work in forest reserve areas, along coastlines, and in sensitive riparian areas may trigger this policy and require additional assessment. Forests OP/BP 4.36 No Additional research and subsequent definition of subprojects during project preparation have shown that this safeguard will not be triggered. Planned watershed management activities and Page 4 of 11 slope stabilization works will not impact the management, protection and/or utilization of forests nor are any projects involving harvesting Public Disclosure Copy or converting forest resources considered under the project. Pest Management OP 4.09 No Specific activities under the project which may involve the incidental use of pesticides or herbicides include termite building treatments, vector control, road maintenance, crop recovery and/or emergency response activities. Nevertheless, the incidental use of pest control measures will be managed by detailing appropriate procedures in the generic standardized EMP for inclusion into contracts. Physical Cultural Resources OP/ Yes Chance-find procedures as well as historic BP 4.11 building screening procedures have been included in the environmental safeguards instruments. Stakeholder contribution to conceptual design of building rehabilitation will also be solicited, if deemed necessary. Indigenous Peoples OP/BP 4.10 No Screening was conducted by the World Bank and an independent consultant during project preparation to determine whether Indigenous Populations are present in the project area. The screening confirmed that while populations who claim indigenous descent exist in the project area, these groups no longer retain the minimum Public Disclosure Copy characteristics necessary to claim indigenous group affiliation under Bank Policy OP/BP 4.10. Involuntary Resettlement OP/BP Yes Prior Bank experience with the type of works 4.12 proposed under this project (e.g. slope and riverbank stabilization, road rehabilitation, improved drainage, emergency shelter retrofits) has shown the possibility of land acquisition (permanent and temporary, voluntary and involuntary) as well as impacts to beneficiary assets or access to assets. The Involuntary Resettlement Policy (OP/BP 4.12) is therefore triggered as a precaution. A Resettlement Policy Framework (RPF) has been developed and publicly disclosed in country and at the Bank’s InfoShop to cover any unanticipated acquisition that emerges during project implementation. The Project will not finance the resettlement of populations living in high risk areas. Page 5 of 11 Safety of Dams OP/BP 4.37 No OP/BP 4.37 has not been triggered as flood control works and river defense structures are a few meters high (at most). The Project will not Public Disclosure Copy finance any works on the John Compton Dam. Projects on International No Planned works under the project are exclusively Waterways OP/BP 7.50 located on the island of Saint Lucia and not in the proximity of any International Waterways, as defined by OP/BP 7.50. Projects in Disputed Areas OP/BP No Planned works under the project are exclusively 7.60 located on the island of Saint Lucia and not in the proximity of any Disputed Areas, as defined by OP/BP 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 proposed project. Identify and describe any potential large scale, significant and/or irreversible impacts: Environmental Assessment OP/BP 4.01. The borrower prepared a project-level Environmental and Social Management Framework (ESMF) to encompass and evaluate potential environmental impacts of the entire program and to screen future projects for additional assessment needs. For relatively simple subprojects and activities (e.g. building rehabilitation), a standard screening procedure and draft contract clauses for environmental mitigation measures have been developed to serve as part of an Environmental Management Plan (EMP) and will be applied (as needed) to construction contracts. This simplified environmental management strategy will suffice in the majority of cases, since most works planned under the project are relatively small-scale in nature. Only minor impacts are anticipated during the construction phase of such works and can be Public Disclosure Copy mitigated with best management practices as well as standard operating procedures (e.g. building rehabilitation or bridge construction). In addition, the ESMF includes a preliminary assessment of potential environmental impacts of the portfolio of subprojects under the DVRP, and identifies several activities which may require additional assessment. Examples of such activities include WASCO waterline easement works in forest reserve areas, SLASPA works along sensitive coastlines as well as road reconstruction works between Venus and Anse la Raye in sensitive riparian areas or in well-conserved zones. These more complex projects as well as other similar road works (e.g. Savannes Bay) will be further assessed upon availability of detailed designs using the principles, guidelines and procedures described in the EMF for assessing the environmental impacts of future subprojects during project implementation. An EIA has already been prepared for the construction of the new Dennery Polyclinic due to potential issues related to siting and medical waste management. Procedures for (a) screening future subprojects, (b) selecting mitigation measures and (c) conducting additional subproject-specific EIAs (if required due to environmental complexity and/ or safeguards triggering) have been defined in the ESMF and respond to the types of projects/ subprojects anticipated under Components 1 and 2. Standard procedures for mitigating environmental impacts of construction, monitoring and reporting are also included. The ESMF provides procedures for the application of Bank safeguards including information on subproject Page 6 of 11 screening and categorization. The ESMF also includes a section with clear safeguards guidelines for emergency investments and works including for the preparation of any safeguards studies prior to commencement of works as pertinent under OP 10.00 (as may be considered under Component Public Disclosure Copy 4). Natural Habitats OP/BP 4.04. This safeguard has been triggered as a precaution due to potential project activities which may occur in highland forest areas, river valleys, coastlines and / or marine areas. The ESMF accounts for natural habitats when screening both known works and any future activities currently undefined. Works in forest reserve areas may include WASCO waterline replacements for the Louisy and Au Leon intakes, which would involve rehabilitation of abandoned or damaged diversions within the reserves and the placement of waterlines across easements through the reserves. SLASPA activities may involve works in sensitive areas along coastlines which could affect coral reefs or marine environments, and would need to be screened for such effects once they have been defined. In addition, the Venus – Anse la Raye road reconstruction project would affect sensitive and potentially well-preserved riparian areas as well as involve earthwork near watercourses and intake areas. Given that such areas are characterized by highly erodible soils, the potential of landslides is duly accounted for. Evaluations will also be made of proposed road rehabilitation works in other potentially sensitive areas such as the southeast coast near Savannes Bay. Finally, landslide stabilization works will be undertaken within the upper watersheds in forest reserves; while the majority involves simple activities and soft engineering works (e.g. check-dams and native re-vegetation), in the event that more complex activities are undertaken, specific mitigation measures may need to be developed. Screening of future subprojects, as described in the ESMF, would determine if additional assessment and specialized mitigation measures would be required for these projects, once detailed designs are developed during implementation. Forests OP/BP 4.36. Forest resource harvesting is currently unanticipated in any project interventions. Additional research and verification throughout project preparation showed that the policy is not triggered. Proposed activities which include development of integrated watershed Public Disclosure Copy management plans as well as to stabilization of landslide-prone slopes in designated forest reserves, do not aim to bring about changes in the management, protection, or utilization of forests, nor are there any projects considered for converting forest lands to other uses. Pest Management OP 4.09. Select subproject activities may require the incidental use of pesticides for termite control in buildings, road maintenance activities or emergency activities such as crop recovery, or vector control. The ESMF provides for restricting pesticide use to licensed providers and other measures to ensure that adequate protection measures are included in the generic EMP for contracting documents. Physical Cultural Resources OP/BP 4.11. This safeguard is triggered as a precaution as project activities may potentially include retrofits of historical buildings, restoration of culturally significant structures and / or chance finds of historically or culturally significant resources during construction of works involving excavations or land clearances. The ESMF includes (and EMPs will include) a "chance-find" procedure, particularly for activities such as major excavations, road realignments or similar works where such assets could be affected. Site screening exercises will be performed to (a) avoid adversely affecting physical cultural resources such as historical buildings and (b) solicit stakeholder contributions to conceptual designs of projects such as building rehabilitation. Page 7 of 11 Involuntary Resettlement OP/BP 4.12. The Client has developed a Resettlement Policy Framework (RPF) to account for any unanticipated land acquisitions that emerge during project implementation. The RPF has been publicly disclosed in-country and at the Bank’s InfoShop. Public Disclosure Copy Additionally, a social assessment has (a) been developed during project preparation, (b) screened all project sites and (c) confirmed that neither land acquisition nor resettlement is anticipated. Should unanticipated land acquisition and/or resettlement be required during implementation, either an abbreviated or full-scale resettlement action plan would be prepared as appropriate and disclosed prior to subproject financing. Past DRM engagements suggest the potential impact a project can have on beneficiary assets or access to assets (e.g. in the case of river bank reinforcement). Resettlement could also result if integrated watershed management plans for flood mitigation projects result in restricted access to protected areas. As no such risks have been found to exist at the time of Appraisal, a Process Framework for Involuntary Resettlement has not been required. Finally, the Project is considering screening criteria to avoid complicated resettlement and/or land acquisition processes for small projects – both to clearly identify cases where lands need to be acquired and establish mechanisms to verify that any land acquisition is carried out through voluntary means. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area: At the time of Appraisal, it was determined that project activities will likely not stimulate any indirect or negative long-term future impacts; however, this aspect would continue to be monitored throughout the duration of project implementation. 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. N/A 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. Public Disclosure Copy Environmental Safeguards. The GoSL has prepared a program-level ESMF to provide preliminary assessments of project activities and to guide project execution for screening possible subprojects. For complex projects, triggers have been defined which would requireadditional studies to comply with safeguards policies. For relatively uncomplicated projects, the ESMF has included generic mitigation measures through the development of a generic EMP, which will also be included in the Operations Manual and ideally reflected in future environmental compliance contracting clauses. For complex projects or activities in sensitive areas, the ESMF has defined criteria to trigger additional assessment requirements. While technical staff of participating Ministries would assist with contract supervision, the PCU will be the final responsible agency for environmental management. In addition to Bank requirements, the PCU would also be responsible for (a) ensuring the proper application of national environmental laws; (b) ensuring environmental compliance in accordance with procedures detailed in the project's Operations Manual; and (c) reflecting such requirements in associated works contracts. A World Bank Environmental Specialist would further provide additional technical support during project implementation. The Sustainable Development and Environment Department (SDED) within the Ministry of Public Service, Sustainable Development, Energy, Science, and Technology provides national supervision of environmental compliance, while receiving technical support from the relevant Page 8 of 11 Ministries and Agencies on an as-needed basis. The PCU will manage and supervise a local environmental consultant hired as-needed during project implementation to support the compliance and collaboration with the SDED and other line Ministries and Agencies. Periodic Public Disclosure Copy supervision by a World Bank Environmental Specialist would be conducted to provide additional support. Component 5 of the Project would also serve to enhance the institutional capacity of SDED through safeguards training to implement the provisions of the Operations Manual. Social Safeguards. The PCU has direct, recent and relevant experience with OP/BP 4.12 from the recently closed DMP II project and the ongoing Hurricane Tomas Emergency Recovery Project – both of which triggered this safeguard. The PCU is therefore familiar with OP/BP 4.12 and related instruments. Nevertheless since there would be multiple sub-projects involving civil works and potential land acquisition, it has been agreed that a part-time social development specialist would be hired to oversee the implementation of the RPF and development of RAPs, as needed. 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. A process of stakeholder identification and consultation is built into the project-level Social Assessment. The SA takes a gender perspective and considers the perspectives of both female and male beneficiaries under this project. The findings of the SA and the views garnered during these consultations have been reflected (when relevant and possible) in project design. The majority of works contemplated involve the repair and retrofit of existing infrastructure. In these cases, impacts to stakeholders would relate to temporary inconveniences associated with construction activities and would be managed to minimize impacts to the greatest extent possible. Advanced public notifications would inform potentially affected persons. Relevant line ministries would assist SDED and the PCU in these efforts. In addition, consultation with stakeholders on the disposition of potential physical cultural resources would be sought as contributions to project conceptual design, in the case of antiquated Public Disclosure Copy or historically valuable structures, possibly meriting preservation activities for reconstruction or rehabilitation activities of schools, clinics, and similar projects. When subproject-specific EIAs are required, specific stakeholders will be identified and public meetings will be conducted to enable the reflection of stakeholder concerns in project design. These requirements have been incorporated into the TORs for EIAs. Projects identified as potentially requiring EIAs include those which demonstrate environmentally complex aspects or which may directly or indirectly affect natural habitats, sensitive areas, or physical cultural resources. Examples of such projects may include SLASPA activities, activities within designated forest reserves such as slope stabilization measures or water diversion infrastructure. Once specific interventions are identified, specific EIAs may be required and will require full engagement of the affected communities through meetings and public consultations. Community comments and concerns would be integrated into the project design, while plans for public engagement during the construction phase of subprojects would be provided as part of the assessment process. A record of public meetings and community engagement activities would be required as part of the assessment and implementation program. B. Disclosure Requirements Environmental Assessment/Audit/Management Plan/Other Date of receipt by the Bank 02-Dec-2013 Page 9 of 11 Date of submission to InfoShop 14-Jan-2014 For category A projects, date of distributing the Executive Summary of the EA to the Executive Directors Public Disclosure Copy "In country" Disclosure St. Lucia 15-Jan-2014 Comments: The Environmental Assessment and Environmental Management Framework were published on the Ministry of Finance and the Ministry of Infrastructure websites on January 15, 2014. Resettlement Action Plan/Framework/Policy Process Date of receipt by the Bank 03-Feb-2014 Date of submission to InfoShop 03-Mar-2014 "In country" Disclosure St. Lucia 15-Jan-2014 Comments: The Resettlement Policy Framework was published on the Ministry of Finance and the Ministry of Infrastructure websites on January 15, 2014. 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? Public Disclosure Copy 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? OP/BP 4.04 - Natural Habitats Would the project result in any significant conversion or Yes [ ] No [ ] NA [ ] degradation of critical natural habitats? If the project would result in significant conversion or Yes [ ] No [ ] NA [ ] degradation of other (non-critical) natural habitats, does the project include mitigation measures acceptable to the Bank? OP/BP 4.11 - Physical Cultural Resources Does the EA include adequate measures related to cultural Yes [ ] No [ ] NA [ ] property? Does the credit/loan incorporate mechanisms to mitigate the Yes [ ] No [ ] NA [ ] potential adverse impacts on cultural property? OP/BP 4.12 - Involuntary Resettlement Has a resettlement plan/abbreviated plan/policy framework/ Yes [ ] No [ ] NA [ ] process framework (as appropriate) been prepared? Page 10 of 11 If yes, then did the Regional unit responsible for safeguards or Yes [ ] No [ ] NA [ ] Sector Manager review the plan? Public Disclosure Copy 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: Name: Tiguist Fisseha Approved By Public Disclosure Copy Sector Manager: Name: Niels B. Holm-Nielsen (SM) Date: 07-Apr-2014 Page 11 of 11