INTEGRATED SAFEGUARDS DATA SHEET APPRAISAL STAGE Report No.: ISDSA6516 Public Disclosure Copy Date ISDS Prepared/Updated: 12-Feb-2014 Date ISDS Approved/Disclosed: 12-Feb-2014 I. BASIC INFORMATION 1. Basic Project Data Country: Gabon Project ID: P143914 Project Name: GABON - SUSTAINABLE MANAGEMENT OF CRITICAL WETLANDS ECOSYSTEMS (P143914) Task Team Salimata D. Follea Leader: Estimated 10-Feb-2014 Estimated 27-Mar-2014 Appraisal Date: Board Date: Managing Unit: AFTN1 Lending Specific Investment Loan Instrument: GEF Focal Biodiversity Area: Sector(s): General agriculture, fishing and forestry sector (100%) Theme(s): Biodiversity (100%) Is this project processed under OP 8.50 (Emergency Recovery) or OP No Public Disclosure Copy 8.00 (Rapid Response to Crises and Emergencies)? Financing (In USD Million) Total Project Cost: 8.47 Total Bank Financing: 0.00 Financing Gap: 0.00 Financing Source Amount Borrower 0.00 Global Environment Facility (GEF) 8.47 Total 8.47 Environmental B - Partial Assessment Category: Is this a No Repeater project? 2. Global Environmental Objective(s) The Development Objective of the proposed operation is to improve management of selected critical wetlands ecosystems, through knowledge creation and capacity building of national entities. Page 1 of 11 3. Project Description 1. The project is designed around five components, the collective aim of which is to help the Government of Gabon implement the recommendations of the Ramsar Convention and the Public Disclosure Copy resolutions of the Conference of the Parties to: (a) improve the level of knowledge of Gabon’s WII; (b) establish a system for monitoring ecological characteristics of wetland ecosystems; (c) establish the conditions necessary for managing an effective WII network in Gabon; and, (d) undertake an economic valuation of wetlands ecosystem services. 2. Component 1 addresses wetland knowledge acquisition (including economic valuation), and establishes a monitoring system for Gabon’s WII. Component 2 strengthens capacity for local management of WII. Cmponent 3 furthers the Nagoya Protocol on Access to genetic resources and the fair and equitable Sharing of Benefits arising from their utilization (ABS). Component 4 establishes the conditions for national level WII management and component 5 focuses on project management. Summaries of these four components plus the fifth management component are presented below. A. Project Components Component 1: Improvement of Knowledge and Monitoring of Selected Critical Wetland Ecosystems (GEF – US$0.550 million). 3. This component will generate knowledge on wetlands in Gabon and set up a reliable monitoring system that can produce early warnings on potential alterations of wetland ecosystems. The component is divided into two sub-components. 4. Sub-Component 1.1: Knowledge creation on wetland ecosystems. This sub-component will support research work on the biological wealth and socioeconomic dimensions of Gabon’s wetland ecosystems. This research will identify and quantify the multiple ecosystem services delivered by Public Disclosure Copy wetlands. The ultimate goal of this information is to help decision-makers better understand the importance of wetlands and the potential trade-offs with other competing activities in the wetlands (with a specific focus on forested wetlands). 5. Targeted research will focus on three selected Ramsar WII sites: Petit Loango/Setté-Cama, Monts Birougou, and Bas Ogooué. The research program will compile existing information, and identify research needed for priority issues. With guidance from the Ramsar Handbooks, a Research Coordinator located in the National Directorate of Environment and Nature Protection (DGEPN) - in consultation with the National Agency for National Parks (ANPN) - will prioritize and oversee environmental and socioeconomic research in the selected three WII sites. Research activities, conducted jointly between national and international research entities, will involve: (i) diagnostic studies; (ii) economic valuation of services delivered by wetlands ecosystems; and (iii) research on traditional uses of natural resources (including medicinal plants). 6. Sub-Component 1.2: Monitoring system for wetland ecosystems. The objectives of this sub- component are to define and operationalize the most appropriate monitoring system for ecological, physicochemical, and socioeconomic characteristics of the wetlands in Gabon. The ANPN has developed management plans, which include monitoring strategies, for the national park areas that are close to or within this project’s selected Ramsar sites. Accordingly, this project will build on the monitoring system work already done by ANPN in Petit Loango and Birougou national parks. It will Page 2 of 11 also benefit from monitoring system development work being done through the French Development Agency (AFD) project in the Pongara and Akanda Ramsar sites. Public Disclosure Copy 8. Component 2: Support to Sustainable Management of Selected Critical Wetland Ecosystems (GEF amount – US$3.110 million). The priority under this component is to promote sustainable management of critical mangrove ecosystems through the following three sub-components: 9. Sub-Component 2.1: Planning for sustainable management of selected sites. The situations of the Ramsar sites in Gabon are quite varied in terms of legal status, geographical and hydrological features, and typology of pressures. As of today, there is no management plan (or any planning tool) that appropriately defines the modalities to support sustainable management of the wetland ecosystems. Therefore, these tools need to be developed, but in a targeted manner to ensure that the specific challenges and threats of the different wetland areas are addressed appropriately. To that end, guided by the Ramsar Handbooks, and in consultation with other government agencies and development partners active in the sites, this sub-component will prepare management plans for the selected Ramsar sites, based on extensive consultative work in those sites, and the results of the research activities undertaken in Component 1. 10. Sub-Component 2.2: Strengthening surveillance capacities in the selected sites. Unless they are included in a national park, most of the existing Ramsar sites do not have adequate monitoring activities, mostly because of insufficient staff on the ground and lack of equipment. The goal of this sub-component is to reinforce the capacity of local people in the three selected WII sites to monitor wetland activities through: (a) Provision of appropriate equipment and infrastructure to reinforce capacities of local staff to properly implement monitoring activities in the selected sites, which would include, for example, vehicles, boats, camping equipment, and the construction of staff quarters; (b) Training of local staff in monitoring activities, such as that delivered to ecoguards in the national parks under the previous GEF-financed project and including conservation software systems Public Disclosure Copy such as MIST/SMART already used by the ANPN for the monitoring of the national parks; (c) Engagement of local communities in wetland monitoring, through regular consultation with the local community management committees, technical assistance (on fisheries, for example), and other education and awareness raising activities. 11. Sub-Component 2.3: Environmentally friendly, community-driven activities in wetlands. The objective of this sub-component is to help communities adjacent to the selected Ramsar sites develop income-generating activities for sustainable wetland management. As appropriate, this will be done in partnership with local NGOs and CSOs; and in collaboration with other government entities, notably those responsible for tourism development, forestry, fisheries, and agriculture. Tourism activities could include, for example, infrastructure (access roads, campsites, docks, boat ramps, watch towers); and community or private enterprises (restaurants and concession stands, lodges, nature guides, transportation services). Apart from tourism, other sustainable economic activities eligible for project financing could include fisheries development, fiber harvesting, apiculture, plant nurseries, horticulture, transformation of agricultural products, NTPF and medicinal herb product development, and small livestock production. 11. Component 3: Implementation of the Nagoya Protocol (GEF – US$1 million). Gabon has clearly led the way in the Africa region, being the first country to ratify the Nagoya Protocol in May 2011 (Gabon was the twenty-second signatory of the Protocol). Moreover, Gabon has already completed a Page 3 of 11 draft national strategy and plan of action to implement the Nagoya Protocol on Access and Benefit Sharing (ABS). The objective of this component is, therefore, to consolidate and implement the measures contained in the strategy document, and thereby operationalize the Nagoya Protocol. Led Public Disclosure Copy by the National Focal Point for the Nagoya Protocol located in the DGEPN, this component will: (i) strengthen the capacity of key Government actors and local communities on ABS procedures; (ii) develop and validate legislative and administrative measures; and (iii) implement the institutional framework for the protocol. 12. Component 4: Strengthen Institutional Framework to support Wetlands Management (GEF – US $3.326 million). Th is Component will establish an institutional framework favorable to the sustainable management of the WII in Gabon at both the national and local levels. The project will establish an MOU with the Ramsar Convention to provide technical assistance to DGEPN for the development and implementation of a national institutional framework for the management of Gabon’s network of Ramsar sites. With guidance from the Ramsar Handbooks, analyses will be undertaken to (i) assess the existing policy framework for wetland protection in Gabon; and (ii) assess the institutional structures currently governing each WII site. The studies will propose recommendations to strengthen the policy and institutional frameworks to better achieve wetland protection objectives. With support from the Ramsar Convention, and based on the data analysis and information obtained in Component 1, and the priority setting and resource use planning work of Component 2, this component will also develop a national wetlands strategy, in consultation as appropriate, with other government DGs. 13. Mapping capacity in DGEPN will also be strengthened to generate wetland maps geocoded with environmental and socioeconomic data. As a basic modality for integrated natural resource management, this component will conduct environmental audits of industrial operations (mining, forestry) operating in and around the three WII sites. To that end, the component will finance technical assistance to strengthen DGEPN capacity by the provision of specialists in environment, fisheries, and social development. These specialists will provide expertise to both DGEPN and ANPN, and it is expected that they will be absorbed by in the DGEPN structure at the end of the project, depending on national budget availability. Public Disclosure Copy 14. Component 5: Project Management, Monitoring and Evaluation (GEF – US$0.485 million). This component supports the overall daily administration of the project, to ensure that regular monitoring and evaluation is carried out, and the results are fed back into decision making on project implementation. As the DGEPN is responsible for the overall administration, coordination, and implementation of the project, Component 5 will support the DGEPN with the recruitment of the following personnel: (i) a specialist/assistant in procurement; (ii) a financial management specialist/ assistant; (iii) a specialist/assistant in monitoring and evaluation. 4. Project location and salient physical characteristics relevant to the safeguard analysis (if known) The project will focus on three Ramsar sites: Bas Ogooué, Monts Birougou, and Petit Loango/Setté- Cama. These sites were selected by the Government based on: (i) the importance of wetland ecosystem services for local populations, and for climate change adaptation and mitigation; (ii) the threats to the wetland ecosystems from competing land uses; and (iii) initiatives already undertaken in theareas. 15. The selection process also prioritized a diverse representation of marine and terrestrial biodiversity. Thus, the three sites chosen represent coastal, alluvial plain, and high interior, heavily forested wetland habitats. Page 4 of 11 a) Bas Ogooué ((862,700 ha) is a large alluvial plain in the west of the country, with lakes, rivers, riparian marshes, savanna, and dense forest. It constitutes the interior delta of the river Ogooué where rivers and lakes combine to provide a navigable waterway, for goods and people, between the Public Disclosure Copy interior towns of Ndjolé, Lambaréné, and Port-Gentil on the coast. The flood plains and the high level of vegetation of the area also provide flood protection to downstream areas. The site is habitat for primates (gorilla, chimpanzee, mandrill), large mammals (hippopotamus, buffalo, elephant, manatee), migrant bird populations, turtles, reptiles (black and Nile crocodiles), and many fish species. Of the three selected sites, Bas Ogooué is the most densely populated, which leads to varying pressures on the wetland areas from fishing, hunting, tourism; and competing land uses such as slash and burn agriculture, and forestry. In collaboration with the Ministry of Water and Forests and the Ministry of Fisheries, WWF has conducted various research, education and awareness activities at this site. b) Monts Birougou (536,800 ha) is a high elevation (800-900 m) forested wetland area interspersed with swamps and savanna. It is an important water tower for Gabon, as it is the source of the Nyanga and Ngounié rivers and their main tributaries. The site is an important breeding and feeding site for different species of freshwater fish. Local people use its ecosystem products for construction, food, and clothing; and the area has cultural and religious value to the country as a whole. The site contains 20 species of primates including gorilla and chimpanzee; other large mammals include both the forest and savanna elephants. Population density is low, but the site is threatened by forestry and mining activities, and destructive (chemical) fishing practices. Some research and planning has been undertaken in this site because the Monts Birougou WII site contains within its boundaries the Birougou National Park, for which the ANPN has prepared a management plan. d) Petit Loango + Setté-Cama. (480,000 + 220,000 ha) These are in fact two linked Ramsar sites that are treated as one site for the purpose of this project. Both are coastal plain wetlands. Petit Loango is set in a mangrove and rainforest environment important for flood control, sediment capture, and bank stabilization. Setté-Cama is a sand plain important for its fish spawning, feeding, and breeding grounds; and water supply to nearby town of Gamba. The sites are important habitat for large mammals (hippopotamus, elephant, manatee), turtles, birds, amphibians, and reptiles. Both sites Public Disclosure Copy benefit from tourism. Both sites have low population density, but both are threatened by nearby oil exploitation. Some research and planning has been done in this site by ANPN, which prepared a management plan for the Loango National Park. The Petit Loango WII site is within the boundary of the Loango National Park, and the Setté Cama WII site falls in its buffer zone. 5. Environmental and Social Safeguards Specialists Lucienne M. M'Baipor (AFTCS) Emeran Serge M. Menang Evouna (AFTN1) 6. Safeguard Policies Triggered? Explanation (Optional) Environmental Assessment OP/ Yes As per its nature, the project is not expected to BP 4.01 generate large scale adverse social or environmental impacts. The operation will not finance any major investments on the ground. Under sub component 2.2, the project will build necessary infrastructure to reinforce capacities of local staff to properly implement monitoring activities in the selected sites. Under sub component 2.3, the project expects to develop Page 5 of 11 tourism activities. All these activities may have environmental impacts even at a very limited scale. An Environmental and Social Management Public Disclosure Copy Framework has been prepared and has been disclosed at the Infoshop on February 7, 2014. Natural Habitats OP/BP 4.04 Yes The wetlands ecosystems are undoubtedly critical ecosystems, the project will enhance the quality of the management of these critical ecosystems and reduce risks associated with potential economic development. Forests OP/BP 4.36 Yes This is triggered because some of the project sites have important mangrove forests. These areas will be subject to adequate management plans during the project implementation. Pest Management OP 4.09 No The project does not involve pest management. Physical Cultural Resources OP/ No The project activities will not involve or affect BP 4.11 physical cultural resources. Indigenous Peoples OP/BP 4.10 Yes There are no indigenous people in the project sites that will be affected by project interventions. This policy is triggered for precautionary measures, because Gabon belongs to the Congo Basin countries where there are pygmies (Cameroon and Congo). An Indigenous Peoples Plan has been prepared and has been disclosed in- country on 06/06/2014 and at the Infoshop on 02/07/2014. Public Disclosure Copy Involuntary Resettlement OP/BP Yes No physical displacement of people is expected. 4.12 However the project expects to prepare management plans of selected RAMSAR sites. To ensure appropriate involvement of local communities, in the event of restriction of access of the aforementioned sites, a ProcessFramework has been prepared and was disclosed in country on 11/24/2013 and in the Infoshop on 02/07/2014 although no involuntary resettlement or limitation of access is anticipated. Safety of Dams OP/BP 4.37 No This policy is not triggered, as there will be no dam construction or rehabilitation of dams that will necessitate dam safety status report. Projects on International No This policy is not triggered, for there are no Waterways OP/BP 7.50 international waterways in the project sites. Projects in Disputed Areas OP/BP No This policy is not triggered because project 7.60 intervention sites are not within disputed areas. II. Key Safeguard Policy Issues and Their Management Page 6 of 11 A. Summary of Key Safeguard Issues 1. Describe any safeguard issues and impacts associated with the proposed project. Identify Public Disclosure Copy and describe any potential large scale, significant and/or irreversible impacts: The overall impact of the project is expected to be positive as the project would finance interventions in biodiversity conservation with control and surveillance to help reduce poaching and human pressure on on the selected sites. By investing in community income generating and sustainable livelihood micro-projects selected through a continued and strengthened consultative and participatory approach, most of the activities are expected to have positive impacts on the quality of life of inhabitants and local communities. Potential adverse environmental impacts associated with implementation of the wetlands management plans are minimal if any, comprising principally those associated with construction of park rangers surveillance posts. It is anticipated that project activities will not lead to land acquisition, nor to major restriction of access to parks and related sources of livelihood. Nevertheless, a Process Framework has been prepared for the project for the (unlikely) event that access to legally designated parks would be restricted.. It is not expected that project activities will affect indigenous people, as there are none in the project areas. However given that Gabon belongs to the Congo Basin where there minority pygmies groups (in Cameroon and Congo), OP. 4.10 has been triggered mainly for precautionary measures in the event of migration within the Basin, thereby creating a potential impact of this minority population. An IPPF will has been prepared by the Government and has been disclosed on 2/6/2014. An Environmental and Social Management Framework (ESMF) has also been prepared by the Government and disclosed on 11/24/2013. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities Public Disclosure Copy in the project area: The project will result in improved quality of life for the community members bordering the selected wetlands sites as the project will develop revenue generating activities, including potential viable tourism products in selected wetlands. Activities for tourismdevelopment could include, for example, infrastructure (access roads, campsites, docks, boat ramps, watch towers); and community or private enterprise (concession stands, lodges, nature guides). Apart from tourism, other sustainable economic activities in the WII area could include, for example, the development of pisciculture in lagoons, fiber harvesting, apiculture, and plant nurseries. This would lead to increased employment and income for skilled and unskilled community members, and indirect employment opportunities from provision of services to construction workers such as sale of food and beverages. Further, the interventions in particular for biodiversity conservation would lead to reduced poaching and human pressure on the fragile wetlands resources. There will be no long term adverse impacts as a result of project activities. 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. No significant adverse impacts are expected. 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 Government prepared an Environmental and Social Management Framework (ESMF) and a Page 7 of 11 Process Framework (PF) to cover rehabilitation of wetlands sites infrastructures and the community micro-enterprises, and to address potential restriction to wetlands resources. These two instruments were disclosed in-country and at the Infoshop prior to appraisal. Public Disclosure Copy Mitigation Measures: The ESMF recommends mitigating measures aimed at ensuring that civil works are executed in an environmentally sound manner; such as sprinkling construction sites with water and limiting construction activities to normal working hours, and notifying the local community in advance if construction activities have to be performed outside these hours. For the construction of park rangers’s lodges, the ESMF and PF also provide guidance on (i) the sourcing of construction materials and the disposal of construction-related wastes; and (ii) generic rules for contractors and construction workers to follow, including prohibitions on hunting, fishing, wildlife capture, illegal bush-meat purchases, burning of vegetation, washing vehicles or changing lubricants in or near waterways or wetlands, and any inappropriate interactions with local residents, along with transparent penalties for non-compliance. The Process Framework describes the participatory process by which to measures will be identified to assist displaced persons in the event of restriction of access to parks. The safeguards instruments were prepared after consultation with key stakeholders both at the national and local levels. The proposal in the process framework to establish committees to manage compensation process in the event of conflicts and possible claims was perceived by the populations as an indication that the project might lead to actual resettlement. The objective of the process framework was therefore better clarified during the consultations and in the revised process framework to clear up any possible misunderstanding of its content. The stakeholders also expressed interest in participating in the project annual work plans elaboration process, as well in trainings provided by the project. These concerns were all noted and recommendations were incorporated in the revised safeguard documents accordingly. The Indigenous Peoples Planning Framework: an IPPF has been prepared given the project location, although it is not expected that project activities will negatively impact indigenous Public Disclosure Copy people. Capacity for Safeguard Implementation: The DGE will recruit an environmental and social specialist or consultant that will be responsible for following up safeguards issues during project implementation. The specialist or consultant will be responsible for (i) preparing the TORs for the EMPs and RAP if needed and (ii) ensuring that the contractors comply with the recommendations of these studies and environmental and social management clauses (inserted into their contract) during the construction phase. The Bank will provide guidance on the elaboration of the TORs and DGE will be responsible for providing overall quality control through the review and clearance of the EMPs and RAPs. Specific capacity building on environmental management and environmental assessment will be provide d to the technical services departments of the DGE and ANPN and other implementing focal points. The World Bank safeguards specialists will provide regular support to the PIU's environmental and social staff during the project support missions. 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. The key stakeholders of the project are the local communities of the three project sites: Bas- Ogoue, Monts Birougou and Petit Loango-Sette Cama. The ESMF and Process Framework have been developed in a participatory manner with these communities. Furthermore, wetlands management plans and annual work plans will be prepared in a consultative and participatory Page 8 of 11 approach, with full involvement of these communities at project implementation stage. The three safeguard instruments have been disclosed in the country on 11/24/2013 and 2/6/2014 (for the IPPF) and at the Bank Infoshop on 02/07/2014. Public Disclosure Copy B. Disclosure Requirements Environmental Assessment/Audit/Management Plan/Other Date of receipt by the Bank 11-Nov-2013 Date of submission to InfoShop 06-Feb-2014 For category A projects, date of distributing the Executive Summary of the EA to the Executive Directors "In country" Disclosure Gabon 24-Nov-2013 Comments: Available at the Ministry of Water and Forestry (Services de la Direction Generale de l'Environnement et de la Protection de la Nature - 5eme etage). Resettlement Action Plan/Framework/Policy Process Date of receipt by the Bank 24-Nov-2013 Date of submission to InfoShop 06-Feb-2014 "In country" Disclosure Gabon 24-Nov-2013 Comments: Available at the Ministry of Water and Forestry (Services de la Direction Generale de l'Environnement et de la Protection de la Nature - 5eme etage). Indigenous Peoples Development Plan/Framework Date of receipt by the Bank 31-Jan-2014 Date of submission to InfoShop 06-Feb-2014 "In country" Disclosure Public Disclosure Copy Gabon 06-Feb-2014 Comments: Available at the Ministry of Water and Forestry (Services de la Direction Generale de l'Environnement et de la Protection de la Nature - 5eme etage). If the project triggers the Pest Management and/or Physical Cultural Resources policies, the respective issues are to be addressed and disclosed as part of the Environmental Assessment/ Audit/or EMP. If in-country disclosure of any of the above documents is not expected, please explain why: C. Compliance Monitoring Indicators at the Corporate Level OP/BP/GP 4.01 - Environment Assessment Does the project require a stand-alone EA (including EMP) Yes [ ] No [ ] NA [ ] report? If yes, then did the Regional Environment Unit or Sector Yes [ ] No [ ] NA [ ] Manager (SM) review and approve the EA report? Are the cost and the accountabilities for the EMP incorporated Yes [ ] No [ ] NA [ ] in the credit/loan? OP/BP 4.04 - Natural Habitats Page 9 of 11 Would the project result in any significant conversion or Yes [ ] No [ ] NA [ ] degradation of critical natural habitats? Public Disclosure Copy 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 4.10 - Indigenous Peoples Has a separate Indigenous Peoples Plan/Planning Framework Yes [ ] No [ ] NA [ ] (as appropriate) been prepared in consultation with affected Indigenous Peoples? If yes, then did the Regional unit responsible for safeguards or Yes [ ] No [ ] NA [ ] Sector Manager review the plan? If the whole project is designed to benefit IP, has the design Yes [ ] No [ ] NA [ ] been reviewed and approved by the Regional Social Development Unit or Sector Manager? OP/BP 4.12 - Involuntary Resettlement Has a resettlement plan/abbreviated plan/policy framework/ Yes [ ] No [ ] NA [ ] process framework (as appropriate) been prepared? If yes, then did the Regional unit responsible for safeguards or Yes [ ] No [ ] NA [ ] Sector Manager review the plan? OP/BP 4.36 - Forests Has the sector-wide analysis of policy and institutional issues Yes [ ] No [ ] NA [ ] and constraints been carried out? Does the project design include satisfactory measures to Yes [ ] No [ ] NA [ ] overcome these constraints? Public Disclosure Copy Does the project finance commercial harvesting, and if so, Yes [ ] No [ ] NA [ ] does it include provisions for certification system? 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? Page 10 of 11 Have satisfactory implementation arrangements been agreed Yes [ ] No [ ] NA [ ] with the borrower and the same been adequately reflected in Public Disclosure Copy the project legal documents? III. APPROVALS Task Team Leader: Name: Salimata D. Follea Approved By Regional Safeguards Name: Johanna van Tilburg (RSA) Date: 12-Feb-2014 Advisor: Sector Manager: Name: Benoit Bosquet (SM) Date: 12-Feb-2014 Public Disclosure Copy Page 11 of 11