The World Bank RIGHTS: Inclusion, Accessibility and Opportunities for Persons with Disabilities in Tamil Nadu (P176404) Concept Environmental and Social Review Summary Concept Stage (ESRS Concept Stage) Public Disclosure Date Prepared/Updated: 09/21/2021 | Report No: ESRSC02261 Sep 21, 2021 Page 1 of 15 The World Bank RIGHTS: Inclusion, Accessibility and Opportunities for Persons with Disabilities in Tamil Nadu (P176404) BASIC INFORMATION A. Basic Project Data Country Region Project ID Parent Project ID (if any) India SOUTH ASIA P176404 Project Name RIGHTS: Inclusion, Accessibility and Opportunities for Persons with Disabilities in Tamil Nadu Practice Area (Lead) Financing Instrument Estimated Appraisal Date Estimated Board Date Social Protection & Jobs Investment Project 2/15/2022 4/15/2022 Financing Borrower(s) Implementing Agency(ies) Republic of India Directorate for the Welfare of Differently Abled Persons , Department for Welfare of Differently Abled Persons Public Disclosure Proposed Development Objective To improve inclusion, accessibility and opportunities for persons with disabilities in Tamil Nadu by strengthening social protection systems and last mile service delivery. Financing (in USD Million) Amount Total Project Cost 232.00 B. Is the project being prepared in a Situation of Urgent Need of Assistance or Capacity Constraints, as per Bank IPF Policy, para. 12? No C. Summary Description of Proposed Project [including overview of Country, Sectoral & Institutional Contexts and Relationship to CPF] The 'RIGHTS” Project aims at ensuring inclusion and accessibility as well as creating opportunities for persons with disabilities in Tamil Nadu, India. The Project focuses on building human capital of persons with disabilities by adopting a holistic approach of creating an enabling environment and addressing the needs of persons with disabilities either through direct interventions or in convergence with the other line departments. The proposed strengthening of social protection systems and last mile service delivery platform will not only help in expanding the outreach and expand Sep 21, 2021 Page 2 of 15 The World Bank RIGHTS: Inclusion, Accessibility and Opportunities for Persons with Disabilities in Tamil Nadu (P176404) coverage of programs for persons with disabilities, but will also support early identification of disabilities as well as setting up family and community based care and rehabilitation services across the state. As part of the opportunities pillar, the project aims to support skills and employment of persons with disabilities. D. Environmental and Social Overview D.1. Detailed project location(s) and salient physical characteristics relevant to the E&S assessment [geographic, environmental, social] Project scope is expected to be state-wide (Tamil Nadu), which is situated in the southern-most part of the Indian Peninsula. It is bound by Eastern Ghats on the north, by the Nilgiris and the Anamalai Hills on the west, by Bay of Bengal on the east, and by the Indian Ocean on the south. State is the sixth most populous state in India with a population of 72 million and a density of 555/sq.km (Census 2011). It is among the most urbanized states with about 48 percent of its population residing in urban areas. The major administrative units constitutes 32 districts, 292 talukas, and 16,682 Revenue villages. There are 12 municipal corporations, 124 municipalities, 528 nagar/town panchayats, 385 block panchayats and 12,524 village panchayats. The state covers an area of 13 million ha and has a coastline of 1,076 kms. The geographical setting of the state makes it vulnerable to natural disasters such as cyclones, floods, extreme heat, severe water scarcity/ droughts, storm surge apart from earthquakes, tsunami, lightening, coastal erosion, sea water intrusion and landslides. More than 26.8 million people in India and 1.18 million in the state live with some form of disability. However, estimation of prevalence of disability remains a key challenge. A recent study that used pooled data from the District Level Household Survey (2012-13) and Annual Health Survey (2012-13) reveals that there are 4550 persons with disabilities amongst every 100,000 people in state. Persons with disabilities often have poor health outcomes, lower Public Disclosure educational achievements, lower economic engagement, higher rates of poverty and vulnerabilities, dependency on others, and they are often isolated from mainstream social, cultural, and political opportunities. Households with a disabled member are more likely to experience material hardship - including food insecurity, poor housing, lack of access to safe water and sanitation, and inadequate access to health care . The project will focus on augmenting the capacity of the Directorate for the Welfare of Differently Abled Persons (Directorate for WDAP) and District Differently Abled Welfare Office (DDAWO). Investments cover construction /upgradation of one-stop Social Care Service Centers at the District/Taluka levels/PHCs, establishment/construction of Early Intervention Centers (EICs) in underserved areas, ensuring extended facilities through mobile outreach services and pilot interventions for accessibility within existing housing projects. The exact locations of sub-projects are currently not known and will only be determined during project implementation stage (Year 1 and 2) keeping the needs, site availability and resources in mind. However, based on the proposed activities and available resources, new physical constructions on green fields or ones that require extensive land acquisition is not anticipated. The program's environmental risks mainly relate to investments for construction. These include likely risks related to construction/renovation works; occupational health and safety (OHS) risks to workers; water stress and water contamination during construction and operation of buildings and; health and safety risks to near-by communities during execution of civil works. Some of the potential social risks anticipated under the project are exclusion of vulnerable sub-groups (women, Scheduled Caste/Scheduled Tribe (SC/ST), Below Poverty Line (BPL) and sexual minorities, land and livelihood related impacts, construction induced health and safety concerns, disrisks anticipated under the project are exclusion of vulnerable sub-groups (women, Scheduled Caste/Scheduled Tribe (SC/ST), Below Poverty (BPL) and sexual minorities, land and livelihood related impacts, construction induced health and safety concerns, discrimination at the Sep 21, 2021 Page 3 of 15 The World Bank RIGHTS: Inclusion, Accessibility and Opportunities for Persons with Disabilities in Tamil Nadu (P176404) workplacepoor working conditions poor working conditions, labor influx and Sexual Exploitation and Abuse/Sexual Harassment (SEA/SH) risks. D. 2. Borrower’s Institutional Capacity The Directorate for WDAP will be the Implementing Agency for the Project. At present, the outreach of the Directorate is upto the district level. The Directorate for WDAP does not have any prior experience of projects financed by multi-lateral agencies. As part of the institutional capacity building mandate, the project will invest in strengthening outreach and institutional capacity of the Directorate for WDAP as the nodal agency for managing the Disability Program throughout the State. This will be done by: (i) augmenting human resource capacities in terms of qualified and trained workforce; (ii) strengthening institutions and implementation modalities at local levels; (iii) developing and utilizing Information Technology platforms (Social Registry & SP delivery systems); and (iv) integrating currently fragmented programs by moving from “scheme to systems” approach. An institutional assessment will be undertaken to understand the current implementation arrangements and to inform the requirements of project implementation at all levels (under Component 4). Both Environmental and Social Assessment (ESA) and the institutional assessment will evaluate the Directorate and DDAOWs’ current institutional capacity and inform the Bank of additional resources required to prepare, manage, monitor and report on environmental and social risks and impacts, including capacity building needs to achieve objectives materially consistent with the Environmental and Social Standards (ESSs). The overall capacity to deal with the environmental, social, health and safety risks will require dedicated time/resources during project preparation and early part of the implementation phase to put the required systems and procedures in place. It is proposed that environmental and social consultants/focal points be housed at the Directorate for WDAP for Public Disclosure overall environmental and social management of the project. The consultants will lead the preparation and implementation of relevant E&S instruments (including mitigation/management plans) for the project and contribute in monitoring and reporting on environmental and social impacts associated with each stage of the project. Given the scope of this proposed project, capacity building initiatives for the Directorate for WDAP, DDAOW, line departments, and other partnering agencies will be taken-up to manage environmental and social risks associated with the project. II. SCREENING OF POTENTIAL ENVIRONMENTAL AND SOCIAL (ES) RISKS AND IMPACTS A. Environmental and Social Risk Classification (ESRC) Moderate Environmental Risk Rating Moderate Environmental risks and impacts may arise from activities such as construction/upgradation of one-stop Social Care Service Centers at the District/Taluka/PHC level, upgrading existing Early Intervention Centers (EIC), establishment of new EICs in underserved areas, extension of mobile outreach facilities in each district of the state and pilot interventions on “accessibility” in the existing housing projects under Component 2. Potential environmental impacts may also result from activities linked with vocational training and rehabilitation centers for persons with disabilities to access educational and employment opportunities (Component 3), if small civil works/infrastructure provisions are required for that purpose. However, the proposed intervention of ‘accessibility audit’ of public infrastructure and facilities under Component 2 offers an opportunity to strengthen policy/codes, introduce measures to eliminate barriers and promote universal access, creating positive effects on the quality of Sep 21, 2021 Page 4 of 15 The World Bank RIGHTS: Inclusion, Accessibility and Opportunities for Persons with Disabilities in Tamil Nadu (P176404) physical/built environment, particularly public infrastructure, and transportation. The preliminary assessment considers, in an integrated manner, the following: (i) type/nature and magnitude of activities proposed under the program; (ii) geographical spread of sub-projects across the state; (iii) baseline conditions, characterized by significant variation in topography, natural environmental conditions, population density and physical/ built environment conditions; (iv) involvement of multiple and diverse stakeholders with varying degrees of institutional capabilities; (v) risks pertaining to inappropriate design of buildings and infrastructure, making the facilities difficult to use by persons with disabilities (due to limited availability of skills/experience in the market on dealing with requirements of ‘universal access’); (vi) potential impacts related to construction and renovation works such as dust, noise and issues pertaining to movement of vehicles and on-site storage of construction materials; (vii) occupational health and safety (OHS) risks to workers; (viii) water stress (the urban areas in the state face high to extremely high water shortages, particularly in summers); (ix) water contamination during construction and operation of buildings; (x) inappropriate storage and/or disposal of debris/construction wastes (including potentially hazardous materials) and; (xi) health and safety risks to near-by communities during execution of civil works. While the environmental impacts are likely to be temporary (limited to construction stage), predictable and reversible, dedicated effort, time and coordination will be required during project preparation and in the first year of project implementation to preclude the possibility of any unwarranted effects on the environment and maximize the opportunities of creating environmentally sustainable facilities. To mitigate the identified environment, health and safety risks, Environmental and Social Management Framework (ESMF), Stakeholder Engagement Plan (SEP), Labour Management Procedures (LMP), and the Environmental and Social Commitment Plan (ESCP), will be prepared in addition to specific social risk management instruments listed in the section below. The environmental risk rating will be reassessed during project preparation based on additional information and detailed analysis to be conducted as part of the ESA process. Public Disclosure Social Risk Rating Moderate The social risk for the project is considered moderate at this stage. Based on a preliminary assessment, the Borrower’s capacity to manage social risks, such as social exclusion of vulnerable and marginalized sub-groups, land and livelihood related impacts, labor influx, Sexual Exploitation and Abuse/Sexual Harassment (SEA/SH) and discrimination at the workplace including health and safety concerns under the project is low. It has been proposed that the project (under Component 4 - Building Institutional Capacity and Support Implementation), either sets up or strengthens its existing systems for coordination, capacity building, monitoring and reporting, including beneficiaries feedback and grievance redressal to address social and environmental risks. While the exact social risks and impacts of this project will only be known during the ESA, some the project activities could potentially lead to: (a) persons with disabilities particularly belonging to vulnerable sub-groups such as women, Scheduled Tribes/Schedule Caste (ST/SC) and Other Backward Castes (OBC), sexual minorities being excluded due to limitations in the targeting mechanisms used that may not be comprehensive; (b) Temporary or permanent loss of land and assets leading to loss of livelihood, in case land is required for any physical investments under the project; (c) Construction induced impacts such as workers’ health and safety and project-induced labor influx during construction of one-stop social care service centers and establishment/upgradation of Early Intervention Centres (EIC); (d) Risks of SEA/SH at the workplace and construction sites, against women and children particularly those with disabilities who are likely to be more vulnerable; and lastly (f) Inadequate monitoring, implementation and inter-departmental coordination on social management for efficient service delivery under the project. To mitigate these risks and to ensure strong engagement with the project beneficiaries, the following instruments will be prepared: Environmental and Social Management Framework (ESMF), Stakeholder Engagement Plan (SEP), Resettlement Policy Framework (RPF), Indigenous Peoples Development Framework (IPDF), Labour Management Procedures (LMP), and the Environmental and Social Commitment Plan (ESCP), which will include the preparation of any follow-on mitigation plans agreed Sep 21, 2021 Page 5 of 15 The World Bank RIGHTS: Inclusion, Accessibility and Opportunities for Persons with Disabilities in Tamil Nadu (P176404) with the Borrower. Further, the project will prepare and implement a comprehensive communication strategy (Component 1) to disseminate information in a format accessible to relevant stakeholders, particularly to all categories of persons with disabilities. B. Environment and Social Standards (ESSs) that Apply to the Activities Being Considered B.1. General Assessment ESS1 Assessment and Management of Environmental and Social Risks and Impacts Overview of the relevance of the Standard for the Project: ESS 1 is relevant for assessing, managing and monitoring environmental and social risks and impacts associated with the project towards ensuring that the operation is environmentally and socially sustainable. By improving the coverage, delivery, and quality of multi-sectoral services for persons with disabilities, the project will contribute to human capital development and income generation for direct beneficiaries as well as reduced expenditures for their households. The project will also contribute to improved efficiency of public expenditure on service provision for persons with disabilities through improved systems for inclusion, access, and opportunities. Benefits will also flow to job seekers who gain employment through the expansion of prevention, care and rehabilitation services financed under this project. Physical investments, particularly rehabilitation/creation of early intervention centers and social care centers would be planned, designed and constructed in a manner that ensures resilience to multiple natural hazards and climate risks. By building adaptive systems and capacities to deal with the uncertainties and shocks in the future, people and assets exposed to climate events will suffer less losses. Public Disclosure Environmental Impacts: Most activities proposed under the project are likely to be environmentally neutral or may have negligible adverse environmental impacts. However, the civil works associated with construction/upgradation of one-stop Social Care Service Centers at the District/Taluka levels/PHCs, establishment/construction of Early Intervention Centers (EICs) in underserved areas, and pilot interventions for accessibility within existing housing projects under Component 2, if not appropriately managed, have the potential to create unwarranted moderate level of environmental impacts in the local context. Potential issues during construction may include: (i) risks pertaining to inappropriate design of buildings and infrastructure, making the facilities difficult to use by persons with disabilities (due to limited availability of skills/experience in the market on dealing with requirements of ‘universal access’); (ii) potential impacts related to construction and renovation works such as dust, noise and issues pertaining to movement of vehicles and on-site storage of construction materials; (iii) occupational health and safety (OHS) risks to workers; (iv) water stress (the urban areas in the state face high to extremely high water shortages, particularly in summers); (v) water contamination (including improper management of wastewater) during construction and operation of buildings; (vi) inappropriate storage and/or disposal of debris/construction wastes (including potentially hazardous materials); (vii) health and safety risks to near-by communities during exceution of civil works, including those associated with the movement of vehicles and; (viii) limited impact on trees/vegetation in and around the construction sites. The environmental impacts from the proposed project activities while limited and localized in context, are likely to stem from poor design (inappropriate designs, choice of technique/s and timing that don’t account for minimization of risks and disruption to services), improper execution of civil works (specifically increasing OHS risks for workers and threats to community safety/well-being) and inadequate or delayed restoration of utilities/facilities (power, water and sanitation) disturbed/snapped on account of civil works. Social Impacts: It is critical, to ensure that the benefits/services supported under the Component 1, 2 and 3 reach all categories of persons with disabilities - most notably women, ST/SC/OBC, sexual minorities and persons with Sep 21, 2021 Page 6 of 15 The World Bank RIGHTS: Inclusion, Accessibility and Opportunities for Persons with Disabilities in Tamil Nadu (P176404) cognitive or emotional disabilities who are at higher risk of exclusion from project benefits. Appropriate measures will be developed to address adverse impacts related to land and livelihood, health and safety, and vulnerable groups including ST/SC and OBC, which are consistent with the mitigation hierarchy and in accordance with all the national laws and regulations including the requirements of ESSs. Environment and Social Management: Based on the recommendations and findings of the ESA, an Environment and Social Management Framework (ESMF), Stakeholder Engagement Plan (SEP), Resettlement Policy Framework (RPF), and Indigenous Peoples Development Framework (IPDF), for the project will be prepared, consulted upon and disclosed in line with the requirements of the ESF by appraisal. The ESMF will include procedures for undertaking screening of sub-projects, exclusion/negative list of activities, a ToR for conducting site-specific Environmental and Social Assessments (ESAs) of sub-projects, and guidance/template for preparing site-specific Environmental and Social Management Plans (ESMPs), including Resettlement Action Plan (RAP) and Indigenous Peoples Development Plan (IPDP) as relevant and necessary. The SEA/SH Prevention and Response Action Plan will form a part of the ESMF to manage risks related to SEA/SH. The ESMF will also include environmental and social guidelines for design of social care and early intervention centers. To further manage social and environmental risks, effective, accessible, and responsive Grievance Redress Mechanism (GRM) will either be setup or existing mechanisms will be scaled up. The MIS system will provide one stop data point for collating complaints (from web, toll-free number and written) tracking the process of redressal with satisfactory feedback for closure. A GRM specifically for all workers will be established, taking into account national labor laws and the requirements of ESS2. The GRM will be in place prior to project effectiveness. Public Disclosure Areas where “Use of Borrower Framework” is being considered: No. use of Borrower Framework is not considered and World Bank’s ESF will apply to the project. ESS10 Stakeholder Engagement and Information Disclosure ESS 10 is relevant for ensuring that a consistent, comprehensive, coordinated and culturally appropriate approach is taken for stakeholder engagement and disclosure of project related information. For this, a Stakeholder Engagement Plan (SEP) will be prepared and disclosed before project appraisal. The SEP will provide guidance on specific steps and actions to be taken during preparation and implementation stages of the project. It will also define the mode and frequency of engagement with stakeholders at various stages of the project cycle. Mapping of project stakeholders- project beneficiaries, incuding disadvantaged or vulnerable groups who might be affected by the project and require special attention early on; and analysis of their needs and levels of influence will be done during preparation of the Stakeholder Engagement Plan (SEP). Appropriate arrangements for SEP implementation, including reporting and its updating (as necessary) will be a condition in the ESCP. Given the extensive nature of project activities proposed in different geographical settings of the state, diverse group of stakeholders will be involved in the project’s decision-making, design and implementation. Currently, the identified key stakeholders include project beneficiaries and a number of interested parties covering: (i) persons with disabilities; (ii) Disabled Peoples Organizations (DPOs); (iii) Self Help Groups; (iv) local communities in the project area; (v) institutional stakeholders such as Department of Health, Education, Public Works, Social Welfare, Housing, and Transport; (vi) local authorities - Municipal/Urban Local Bodies, Gram Panchayats under whose jurisdiction the rehabilitation of existing EICs or construction of new Social Care Centers will be carried out; (vii) civil society Sep 21, 2021 Page 7 of 15 The World Bank RIGHTS: Inclusion, Accessibility and Opportunities for Persons with Disabilities in Tamil Nadu (P176404) organizations; (viii) corporates and trade unions; (ix) consultants to be engaged for project preparatory surveys and studies/assessments; (x) other project beneficiaries and; (xi) contractors. The composition of the stakeholder groups may change depending on the final chosen project interventions and the specific geographical areas where the project interventions will be made. The SEP will include measures on how to engage with all categories of persons with disabilities, who are the project’s main beneficiaries. Disadvantaged and vulnerable groups could include sub-groups belonging to the following categories: scheduled tribes, scheduled castes, below poverty line, senior citizens, sexual minorities and women facing intersectional disadvantages. Attention will also be given to family members and/or caregivers providing support for a household with a disabled person, as they are often unable to participate/engage because of their caregiving responsibilities. Project beneficiaries and other interested parties (OIPs) will have access to a GRM to raise concerns and grievances and the mechansim will be described in the SEP. The proect will support beneficiaries’ satisfaction surveys combined with social audit tool to evaluate public satisfaction of the services. The SEP will also include Citizens Engagement Indicators to track the implementation of participatory approaches by the project. The COVID-19 pandemic poses a challenge for stakeholder engagement and disclosure of information, as stakeholder engagement and consultation processes cannot be conducted as per normal ESS 10 requirements. Depending on the situation with COVID-19, a mix of conventional forms/media for information dissemination and virtual modes, mobile phone-based communication etc. for soliciting feedback and engaging different stakeholders will be used during project preparation. As long as COVID-related restrictions place limitations on traditional forms of stakeholder engagement, the requirements of ESS 10 will be met by following guidance set out in the World Bank’s “Technical Note: Public Consultations and Stakeholder Engagement in WB-supported operations when there are constraints on Public Disclosure conducting public meetings” (March 20, 2020). The SEP will address timing and methodologies for meaningful and participatory consultations, including arrangements for information disclosure to stakeholders. The Directorate for WDAP will disclose the ESF instruments that include ESMF, SEP, RPF, IPDF and ECSP before project appraisal to allow stakeholders to be informed about the proposed project activities, potential environmental risks/impacts and mitigation/management plans. The implementation agencies will continue to engage with project beneficiaries and OIPs during project implementation in a manner appropriate to the nature of their interests and potential environmental and social risks/impacts of the project. Additionally, communication and awareness raising initiatives is a central element to this project. The project will commission a Communications Needs Assessment as the first step towards developing the comprehensive Communications Strategy for engaging with stakeholders on an ongoing basis (Component 1). It is important to separate this activity from the stakeholder engagement planning process to meet the obligations of ESS 10, but it is equally important to note some of the synergies between the two processes, which will be leveraged to the extent possible. B.2. Specific Risks and Impacts A brief description of the potential environmental and social risks and impacts relevant to the Project. ESS2 Labor and Working Conditions ESS 2 is considered relevant to the Project. Sep 21, 2021 Page 8 of 15 The World Bank RIGHTS: Inclusion, Accessibility and Opportunities for Persons with Disabilities in Tamil Nadu (P176404) The project will involve: a) direct workers employed specifically by the implmentation agencies for the project; and b) contracted workers engaged in construction works and consultancy services firms for specific deliverables and technical support to Directorate for WDAP. Involvement of community workers is not envisaged given the technical nature of the project. Construction work may require migrant workers from other parts of the state and sometimes from other states depending on the contractors’ strategy and requirement of skill sets. However, the majority of the labor force would be generally available within the state as the works largely relate to rehabilitation and construction of buildings. The Labour Management Procedures (LMP) will be prepared and disclosed by project effectiveness and will include procedures and the details of labor to be used in the activities directly supported by the project throughout its lifecycle. It will also include terms and conditions of employment, non-discrimination and equal opportunity, workers’ organization, the prohibition of child and forced labor, and contain a worker’s grievance mechanism in accordance with the national laws and ESS 2 requirements. The grievance mechanism will contain stipulations for sensitive grievances, including those related to SEA/SH. The relevant staff of the Implementation Agencies, line departments and direct workers, including contract workers will also be subject to and trained on codes of conduct, which include SEA/SH prevention measures, for interacting with local communities. Preparation of ESA will assess occupation health and safety issues/risks, for which required OHS plan will be prepared and integrated into the LMP. All works and operations will be planned, designed and implemented to comply with the World Bank Group’s Environment, Health and Safety guidelines. The bidding documents for construction works will include reference to the LMP and the national/state laws on labor welfare to comply with the requirements of both ESS2 and country systems. Public Disclosure ESS3 Resource Efficiency and Pollution Prevention and Management The principles and requirements laid down in ESS 3 are relevant to the project. Activities pertaining to one-stop Social Care Service Centres, Early Intervention Centres, extension of mobile outreach facilities and pilot interventions in housing projects would consider resource efficiency and pollution management aspects during design/Detailed Project Report (DPR) preparation and construction stage. The purpose will be to improve the quality of physical environment, enhance health/safety and reduce the environmental footprint linked to use and operation of the buildings in a cost-effective manner while keeping the concept of universal access to the fore. For improving resource efficiency, the considerations will include: (a) improving natural light and ventilation (when possible depending on the nature/type of building proposed), (b) increasing water efficiency and, (c) enhancing energy efficiency. For pollution prevention and management, focus will be on: (i) debris/ construction waste management; (ii) run-off/silt control at work sites to prevent sedimentation and any possible contamination of water sources during both the construction and operation phase; (iii) management of hazardous wastes (if any, which will be ascertained as part of ESA) and; (iv) storage and management of construction materials to prevent ground/soil contamination. New building designs and construction will adopt Green Building norms, which fully align with resource efficiency and pollution prevention concepts. To create an enabling mechanism for integrating resource efficiency and pollution prevention/ management, the ESMF will include ‘Environmental Guidelines for Civil Works’. Sep 21, 2021 Page 9 of 15 The World Bank RIGHTS: Inclusion, Accessibility and Opportunities for Persons with Disabilities in Tamil Nadu (P176404) ESS4 Community Health and Safety ESS 4 is considered relevant to the Project. One risk factor is related to COVID-19 where poor community engagement practices could raise exposure risk to the community and the beneficiaries (particularly disability groups who are aged, or with limited mobility or have trouble undertanding information or practicing preventive measures), which could lead to further spread of the disease on account of project activities. As mitigation measures, the Directorate for WDAP will design and implement provisions on how to engage with all categories of persons with disabilities, communities and beneficiaries to prevent or minimize the spread of COVID-19. A second factor relates to the risk associated with project induced labor influx which could expose local communities to other public health risks (communicable diseases), and sexually transmitted diseases, such as HIV/AIDS, as well as SEA/SH, child and forced labor. The third factor relates to health and safety risks to the local communities due to movement of vehicles and exposure to hazardous materials associated with construction/ renovation works. The Directorate for WDAP will propose measures for mitigating risks associated with labor influx and other construction related activities, and develop a SEA/SH Prevention and Response Action Plan as part of the ESMF applicable to project workers (direct and contract), community and project beneficiaries. Labor influx and SEA/SH related provisions will be informed by the World Bank’s Good Practice Note on Addressing Sexual Exploitation and Abuse and Sexual Harassment (SEA/SH) in Investment Project Financing and the Guidance Note on Managing the Risks of Adverse Impacts on Communities from Temporary Project Induced Labor Influx. The bidding documents for the construction works will include requirements to prepare and implement site specific community health and safety plans, which would address all the above identified issues. The ESMF will include requirements for monitoring and reporting of aspects covered under ESS 4. Public Disclosure ESS5 Land Acquisition, Restrictions on Land Use and Involuntary Resettlement The National law on Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (RFCTLARR Act, 2013) and State Rules that meets the requirements of ESS5 will be applied in addition to the ESF standard. The project activities under Component 2 on developing accessible public infrastructure, housing and transportation as well as setting up of one- stop social care service centers, EIC, and Basic Care and Rehabilitation Centers, may potentially result in land acquisition and resettlement impacts although in a limited scale. The project footprint is currently not known and will be finalized during project implementation. To mitigate these risks, the Borrower will undertake sub-project level impact assessment on communities, businesses and common property, livelihood activities, and issues related to hindering access to neighboring settlements. Land acquisition, if required will be kept minimum with feasible design alternatives. A Resettlement Policy Framework (RPF) of the project will be prepared following the national RFCTLARR Act, 2013, Tamil Nadu RFCTLARR Rules and the requirements of ESS5, which will be adopted and applied for preparation of Resettlement Action Plans (RAP) for the sub-projects (if required) after they are identified, and their location, scope and scale of land requirement is known. The RPF will describe the different populations that could potentially be affected, the types of losses foreseen, and the compensation that will be offered to offset losses and restore livelihoods. The RPF will be reviewed, consulted upon, approved, and disclosed both in the country and on the World Bank’s external portal prior to the appraisal of the project. Sep 21, 2021 Page 10 of 15 The World Bank RIGHTS: Inclusion, Accessibility and Opportunities for Persons with Disabilities in Tamil Nadu (P176404) ESS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources Based on preliminary assessment, impacts on biodiversity and habitats, including ‘protected areas’, ‘critical natural habitats’, and/or ‘species with critical biodiversity value’ are not expected. However, the project currently envisages new/greenfield construction for one-stop Social Care Centers and EICs. Therefore, even if impacts are currently envisaged to be negligible, the requirements of ESS 6 to avoid sensitive locations and prevent negative impacts on biodiversity/natural habitats will be applied. An environment screening will be undertaken for each proposed sub-project to assess whether it is located in habitat considered to be a ‘protected area’, ‘critical natural habitat’, and/or associated with ‘species with critical biodiversity value.’ The ESMF will include an exclusion/negative list of activities that will eliminate the possibility of supporting sub-projects in such locations, including forest areas and eco-sensitive zones. Provisions will also be made in the bidding document to ensure that no materials for construction are sourced from any critical habitats, protected areas, forest areas, eco-sensitive zones or any recognized areas of high biodiversity for works/activities supported under the project. Based on the location of project interventions (which is not known at this stage) and the findings from the ESA (which will be used for the preparation of an ESMF), relevant measures if required, to exclude certain sub-projects and avoid negative impacts on ‘modified habitats’ and biodiversity will be taken-up under the project to fulfill requirements laid out in ESS 6. This will include measures in the ESMPs to prevent any possible impact on aquatic life (due to discharges from worksites and/or dumping of debris in water bodies), particularly in sites close to water bodies or in hilly areas of Tamil Nadu, where this is a possibility. Further, in case there is any requirement of tree felling for construction works under the project, requisite permission will be obtained from the Forest Department/Competent Authority prior to initiating civil works and provisions for Public Disclosure compensatory plantation in line with regulatory norms will be built into the Detailed Project Report/estimate of the concerned sub-project. ESS7 Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local Communities The comprehensive National and state laws and policies safeguarding the rights and interests of the Indigenous people, recognized as scheduled tribes in India is fully aligned with the requirements of ESS 7. As per 2011 Census, Tamil Nadu has 7.21 lakh tribal populations which constitutes 1.10% of the state’s total population. There are 36 tribes and sub-tribes, and six particularly vulnerable tribal groups (PVTGs) in Tamil Nadu. While tribal groups in Tamil Nadu are distributed in almost all the districts of the state, relatively higher % of tribal population is noted in the Nilgiris and Dharmapuri districts. Tamil Nadu has a significant disabled population which falls under the ST categories, which require special attention in order to promote equitable access to benefits or to mitigate adverse impacts of the project. As per Census 2011, disability rate in Tamil Nadu among the Scheduled Tribes is 1451 per 100 000. Further, analysis of disabilities by age, gender, and type of residence (urban/rural) showed that disability rates were comparatively higher in rural areas. Considering these intersectional challenges, the Borrower will prepare an Indigenous Peoples Development Framework (IPDF) to ensure that the project enhances opportunities for vulnerable beneficiaries to participate in, and benefit from the development process. A site- specific Indigenous Peoples Development Plan will be prepared for sub-projects located in underserved or remote locations, that have significant ST population. The IPDF and site specific IPDP (wherever needed) will be reviewed, consulted upon, approved, and disclosed both in the country and on the World Bank’s external portal prior to the appraisal of the project. Sep 21, 2021 Page 11 of 15 The World Bank RIGHTS: Inclusion, Accessibility and Opportunities for Persons with Disabilities in Tamil Nadu (P176404) ESS8 Cultural Heritage Given the vast geographical area of the state across which sub-projects would be located (including green-field construction of buildings/facilities under Component 2), there is a possibility of cultural heritage related concerns coming-up in case of certain sub-projects under the proposed operation. The identified sub-projects will be screened for potential cultural heritage impacts. Consultations with communities will also be utilized to screen any sensitive issues related to cultural resources. The ESA would, in any event, evaluate any direct or indirect impact of project activities on cultural assets and determine the presence of any other such resources that may not be listed with national or state governments (Archeological Survey of India) but could be of local significance. Depending on the determination of the nature and scale of the risks and possible adverse impacts, mitigation measures or a plan will be prepared as part of the ESMPs and will be reflected in the ESCP, as appropriate. Any such identified cultural heritage impacts and/or chance finds will be dealt with in line with national legal requirements and Bank’s requirements set forth under ESS 8 of ESF. Procedures for handling chance finds will be prepared as part of the ESMF and will be included in the ESMPs and the Bidding Documents to handle any such situation that may come-up during project implementation. ESS9 Financial Intermediaries Public Disclosure No involvement of Financial Intermediaries (FI) is proposed or envisaged in the project. B.3 Other Relevant Project Risks 1) Directorate for DWAP, the nodal implmentation agency for the project doesn’t have prior experience with World Bank-financed projects. 2) An additional key institutional challenge centers around the need for strong coordination abilities at the Directorate for WDAP level given the need to work closely with a large number of stakeholders/line departments (e.g. Education Department, Public Works Department, Housing Board, Health Department, etc.) to implement interventions under Component 1 and 2. 3) The ongoing COVID-19 global pandemic is also a risk for project preparation and implementation. Under such circumstances, preparation and implementation of the project activities, particularly, field surveys, assessments requiring field work and civil works may experience delays. Supervision of activities may also be a challenge if COVID- situation worsens and restrictions are once again enforced. C. Legal Operational Policies that Apply OP 7.50 Projects on International Waterways No OP 7.60 Projects in Disputed Areas No Sep 21, 2021 Page 12 of 15 The World Bank RIGHTS: Inclusion, Accessibility and Opportunities for Persons with Disabilities in Tamil Nadu (P176404) III. WORLD BANK ENVIRONMENTAL AND SOCIAL DUE DILIGENCE A. Is a common approach being considered? No Financing Partners Not applicable B. Proposed Measures, Actions and Timing (Borrower’s commitments) Actions to be completed prior to Bank Board Approval: The following documents/actions would be required prior to Bank Appraisal for this operation to allow for an informed decision-making, commensurate with issues/risks identified during project preparation: 1) Environment and Social Management Framework (ESMF) (to guide preparation and implementation of multiple sub-projects/building works located across the state for standardization/uniformity and to deal with a situation when sub-projects would be known after appraisal/Board presentation) 2) Stakeholder Engagement Plan (SEP) 3) Resettlement Policy Framework (RPF) (to guide in the preparation of Resettlement Action Plan once the sub- projects or individual project components are defined and the necessary information becomes available to assess the risk of economic and/or physical displacement.) 4) Indigenous Peoples Development Framework (IPDF) (to guide in the preparation of Indigenous Peoples Development Plan once the sub-projects or individual project components are defined and the necessary information Public Disclosure becomes available to assess the risks on vulnerable groups such as Scheduled Caste/Scheduled Tribes, particularly vulnerable tribal groups and those below poverty line.) 5) Environmental and Social Commitment Plan (ESCP) 6) Institutional arrangements to facilitate application and implementation of ESF instruments 7) Disclosure of ESMF, SEP, RPF, IPDF, and ESCP in line with requirements set forth in the World Bank policies on Disclosure and ESF. Possible issues to be addressed in the Borrower Environmental and Social Commitment Plan (ESCP): The following key aspects are likely to be a part of Borrower's ESCP: 1) Staffing for Environment Management at the state and district level 2) Staffing and institutional capacity to manage social risks/impacts at state, district and sub-divisional/taluka level 3) Disclosure of documents 4) Preparation and implementation of specific assessments/plans to meet the requirements set forth in ESSs (sub-project/site specific instruments will be required in Year 2 and 3 of project implementation once sub-projects and their locations are idnetified and screened) 5) Preparation and implmentation and monitoring of Labour Management Procedures (LMP), including site specific Labour Influx Management Plan 6) Implementation of the ESMF, SEP, RPF and IPDF (and updating, as required) 7) Management of Contractors 8) Provisions for worksite safety and labor management, including OHS aspects and traffic safety Sep 21, 2021 Page 13 of 15 The World Bank RIGHTS: Inclusion, Accessibility and Opportunities for Persons with Disabilities in Tamil Nadu (P176404) 9) Prevention and response to Sexual Exploitation and Abuse/ Sexual Harassment (SEA/SH) risks 10) Processes and timelines for obtaining of requisite statutory clearances 11) Training and Capacity Building Plan of Project Officials, Contractors, and other key staff 12) Provisions for managing unanticipated Environmental and Social Risks/Impacts 13) MIS system for evidence-based reporting on (a) social inclusion that covers the vulnerable group and gender, (b) SEP, (c) communication and outreach program, (d) RAP, (e) IPDP, (f) compliance with labour welfare laws and LMP, (g) preventive action plan on SEA/SH-GBV, (h) GRM and (i) environment, health and safety management. 14) To facilitate real time tracking of implementation of actions supporting the environment and social risk management and opportunities, mobile apps will be developed to upload data/information on the MIS from the field which will be geo-referenced. C. Timing Tentative target date for preparing the Appraisal Stage ESRS 15-Dec-2021 IV. CONTACT POINTS World Bank Contact: Srinivas Varadan Title: Senior Social Protection Specialist Public Disclosure Telephone No: 5785+79127 Email: svaradan@worldbank.org Contact: Pravesh Kumar Title: Senior Social Protection Specialist Telephone No: 5785+79189 / 91-11-4147-9189 Email: pkumar11@worldbank.org Borrower/Client/Recipient Borrower: Republic of India Implementing Agency(ies) Implementing Agency: Directorate for the Welfare of Differently Abled Persons Implementing Agency: Department for Welfare of Differently Abled Persons V. FOR MORE INFORMATION CONTACT Sep 21, 2021 Page 14 of 15 The World Bank RIGHTS: Inclusion, Accessibility and Opportunities for Persons with Disabilities in Tamil Nadu (P176404) The World Bank 1818 H Street, NW Washington, D.C. 20433 Telephone: (202) 473-1000 Web: http://www.worldbank.org/projects VI. APPROVAL Task Team Leader(s): Pravesh Kumar, Srinivas Varadan Practice Manager (ENR/Social) Kevin A Tomlinson Recommended on 07-Sep-2021 at 13:09:57 GMT-04:00 Safeguards Advisor ESSA Kevin A Tomlinson (SAESSA) Cleared on 21-Sep-2021 at 07:40:57 GMT-04:00 Public Disclosure Sep 21, 2021 Page 15 of 15