The World Bank RESTRUCTURING ISDS Low Income Community Housing Support Project (P130710) Integrated Safeguards Data Sheet Restructuring Stage Restructuring Stage | Date ISDS Prepared/Updated: 15-Mar-2021| Report No: ISDSR31720 Regional Vice President: Hartwig Schafer Country Director: Mercy Miyang Tembon Regional Director: John A. Roome Practice Manager/Manager: Robin Mearns Task Team Leader(s): Sonya M. Sultan, Sabah Moyeen The World Bank RESTRUCTURING ISDS Low Income Community Housing Support Project (P130710) . I. BASIC INFORMATION 1. BASIC PROJECT DATA Project ID Project Name P130710 Low Income Community Housing Support Project Task Team Leader(s) Country Sonya M. Sultan, Sabah Moyeen Bangladesh Approval Date Environmental Category 05-Apr-2016 Partial Assessment (B) Managing Unit SSAS1 PROJECT FINANCING DATA (US$, Millions) SUMMARY -NewFin1 Total Project Cost 57.50 Total Financing 57.50 Financing Gap 0.00 DETAILS -NewFinEnh1 World Bank Group Financing International Development Association (IDA) 50.00 IDA Credit 50.00 Non-World Bank Group Financing Counterpart Funding 7.50 Borrower/Recipient 7.50 2. PROJECT INFORMATION The World Bank RESTRUCTURING ISDS Low Income Community Housing Support Project (P130710) PROG_INF O Current Program Development Objective The Project Development Objective is to improve shelter and living conditions in selected low income and informal settlements indesignated municipalities in Bangladesh . 3. PROJECT DESCRIPTION This ISDS has been updated for the proposed restructuring of the Bangladesh Low-Income Community Housing Support Project (LICHSP) under implementation by the Government of Bangladesh through the National Housing Authority (NHA) and Palli Karma sahayak Foundation (PKSF). The proposed restructuring is sought to make changes to the results framework, project scope and cost, loan closing date, disbursement categories, and the implementation schedule. The project was approved on April 5, 2016 with five components: A. Community mobilization and planning, B. Community improvements and upgrading, C. Shelter lending support, D. Monitoring and evaluation, and E. Project management. Project components A, B, D and E are managed and implemented by NHA. PKSF is the implementing agency for Component C. The project became effective on October 20, 2016 and the credit closing date is December 31, 2021. The project suffered delays caused by COVID-19 in the past 16 months. The LICHSP restructuring, in summary, involves the following change: a) Extending the project closing date by one year (from 31st December 2021 to 31st December 2022); b) Partial cancellation of USD 6 million from Project Components A, B, D, E and PPA financing (reducing scope); c) Reducing geographical scope of implementation from 3 cities to 2 cities; d) Addition of a new disbursement/withdrawal category under Project Component C; e) Reallocation of financing from the existing sub-component 3b to the new disbursement/withdrawal category 3c; f) Modification in the results framework to include two additional intermediate indicators; and g) Activation of the project retroactive financing clause. Changes in the allocation of Bank financing to Components A, B, D, E and PPA financing amounting to a total partial cancellation of USD 6 million from NHA components. a) Planned spending under Component A has decreased by USD 1.03 million (from IDA credit), partly because NHA has dropped working in a third city – namely Narayanganj. The project is currently working for housing improvement in 17 selected low-income settlements: 12 in Sirajganj City and 5 in Comilla City benefiting a total of about 5,285 low income community households. b) NHA has proposed reducing the allocation of Component B by USD 3.13 million to reflect the reduced scope of primary, secondary and tertiary infrastructure provision resulting from the exclusion of project activities in Narayanganj. The reduction also takes into account the relatively small-scale infrastructure at the settlement level against larger volume of sub-projects and contracts planned at the preparation stage. The World Bank RESTRUCTURING ISDS Low Income Community Housing Support Project (P130710) c) NHA has proposed a marginal reduction of USD 0.15 million to the allocation of Component D for monitoring and evaluation based on spending projections till December 31, 2022. d) NHA has proposed reducing the allocation of Component E by USD 1.60 million after considering projected spending towards project management costs until December 31, 2022. e) PPA financing allocation has reduced by USD 0.09 based on actual spending documented under the PPA facility. The NHA restructuring also proposes inclusion of the retroactive financing clause in the financing agreement to document outstanding expenses made by NHA prior to project signing. The PSKF restructuring proposes financing for a new activity under Project Component C - a “Housing Microfinance Risk Management Support Fund (RMSF)� as part of Shelter Component and Lending activities. A new credit line for RMSF has been proposed to extend emergency loans to active housing loan borrowers affected by COVID-19, to support income generation and the revival of livelihoods disrupted by the pandemic. The restructuring proposes to finance the RSMF by reallocating unspent funds from the existing sub-component 3b on Technical Assistance. Environmental and Social Safeguards Management Safeguards performance under the original project has been satisfactory. Site specific safeguards screening, Environmental Management Plans (EMPs) and Social Management Plans (SMPs) have been prepared for infrastructure activities (subprojects) in selected communities. The SMPs provide guidance and document beneficiary participation in subproject cycle inclusive of social and gender groups. The EMPs guide subproject design for safe drinking water, drainage, and waste disposal system in targeted communities, and managing noise and dust pollution, workers health and safety, and risk of COVID-19 infections during construction. The project is benefitting around 5,285 households in 17 low income communities across two cities: 12 in Sirajganj and 5 in Comilla. The third city, Narayanganj was dropped before initiating any activity there. As of June 2021, EMPs and SMPs have been agreed with the Bank for 10 communities and followed in subproject cycle while drafts are ready for the remaining 7 communities. No Resettlement Plan was prepared for any of the subprojects as involuntary displacement was completely avoided following in-situ upgrading in all settlements except re-blocking in Kobdaspara, Sirajganj. Voluntary temporary relocation of beneficiary households during the construction period of 18 months was agreed and incentivized with construction of foundation of main housing structure at the housing plots allocated to them. They have currently moved temporarily to rented houses, on relatives’ land or on other public land. Name of Settlements in Beneficiary EMP/SMP Name of Settlements in Beneficiary EMP/SMP Sirajganj Municipality Households Status Cumilla City Corporation Households Status (Nos.) (Nos.) 1 Pramanik Para 215 Finalized 1 Kazipara 277 Finalized 2 Kobdas Para 329 Finalized 2 Unishar Moddhyapara 256 Finalized 3 Chowdhuri Para 53 Finalized 3 Unaisha Purbopara 220 Draft 4 Shahidganj 299 Finalized 4 Laksmipur/Ram Manik 180 Draft 5 Halim O Tara 289 Finalized 5 Madhya Ashrafpur 210 Draft 6 Masumpur 219 Finalized 7 Rahmatganj Millgate 260 Finalized The World Bank RESTRUCTURING ISDS Low Income Community Housing Support Project (P130710) 8 Rahamatganj Goli 350 Draft 9 Diar Dhangora 350 Draft 10 Kalibari 300 Draft 11 Janpur 632 Draft 12 Malshapara 501 Finalized 3797 1143 PKSF is working in their own selected communities including the NHA settlements through their partner NGOs (POs). The POs follow project housing guidelines for selecting beneficiaries and identifying their loan proposals. The POs prepare housing loan proposals for the beneficiary households through E&S screening and affordability analysis. The female spouse in the borrower households are party to the housing loan agreements, either as the main borrower or as co-applicant with their male spouse. Owing to the participatory methods used for project implementation, no complaints or concerns have so far been formally raised with the project GRM. The proposed restructuring does not envisage any changes to the applied Environmental and Social (E&S) instruments and does not trigger any new safeguards operational policies as the activities remain similar in nature, in the already selected communities, where the issues are already known and are being managed by EMPs and SMPs. There are no legacy issues or risks of unmet expectations among potential beneficiaries from the project’s reduced geographical scope owing to the dropping of the third city and the reduction in allocation under NHA components from the proposed partial cancellation. The proposed new subcomponent of provisioning a revolving RMSF under the restructuring is for supporting the existing housing loan borrowers affected by COVID-19 pandemic. There will not be any new housing loan proposals under the RMSF generating any new risks. The EMF and SMF adopted for the NHA components and the abbreviated EMF adopted for PKSF operations under the original project will remain valid after restructuring. The PKSF POs will identify active borrowers affected due to impact of COVID-19 pandemic for the RMSF sub-loans following the RMSF eligibility criteria avoiding any discrimination and any new environmental risks or impacts. Project’s SEA/SH risk is rated to be low using the online risk rating tool and will remain so after restructuring. PKSF will however, assist the POs in enhancing their capacity to manage the risks of SEA/SH including domestic violence against women and establish risk management protocols strengthening the project GRM. . 4. PROJECT LOCATION AND SALIENT PHYSICAL CHARACTERISTICS RELEVANT TO THE SAFEGUARD ANALYSIS (IF KNOWN) The LICHSP was supposed to be piloted in three municipalities to start (Comilla, Sirajganj, and Narayanganj), which were selected based on a multi criteria analysis: the class and population of towns, the presence of urban poverty programs and organized urban poor communities, levels of community savings in the town, willingness of the municipality and local government to participate in the project, geographical variation, etc. However, NHA has dropped Narayanganj City Corporation from the project and taken additional settlements in Sirajganj Municipality and in Comilla City Corporation. The project will improve living conditions of the urban poor in selected communities across Sirajganj Municipality and Comilla City Corporation, through a community-driven approach. A total of 17 sites have identified, 12 in Sirajganj and 5 in Comilla. The project is The World Bank RESTRUCTURING ISDS Low Income Community Housing Support Project (P130710) expected to significantly improve social and environmental outcomes for urban poor populations since each participating community will determine improvement and upgrading packages that would be customized based on community preferences and needs. PKSF, which is piloting housing loan products in additional municipalities outside the initial project areas and under the restructuring, is planning to introduce a new product (RMSF) for emergency loans to active borrowers affected by the COVID-19 pandemic. 5. ENVIRONMENTAL AND SOCIAL SAFEGUARDS SPECIALISTS ON THE TEAM Md. Akhtaruzzaman, Social Specialist Iqbal Ahmed, Environmental Specialist SAFEGUARD_TABLE 6. SAFEGUARD POLICIES TRIGGERED Safeguard Policies Triggered Explanation While the impacts of community led settlement upgrading interventions are expected to be largely beneficial, some minor to moderate impacts may occur during the construction phase which are mostly on-site and can be avoided or minimized through concerted efforts. Since the project will involve planning and implementation of multi- sectoral package of basic tertiary infrastructure and services including affordable houses for urban poor community in selected secondary towns, no long term or irreversible adverse environmental impacts are envisaged. Considering the nature and magnitude of potential environmental impacts from community upgrading infrastructures, the LICHSP has been classified as category ‘B’ project. Environmental Assessment (OP) (BP 4.01) Yes As slums or communities to be upgraded were not fully identified or details of sub-project interventions that may have environmental impacts were not available at appraisal, a framework approach has been adopted. The NHA developed an Environmental Management Framework (EMF) and a Social Management Framework (SMF) those provide tiered approach of environmental and social screening, tools to identify potential environmental and social risks in sub-projects, and measures to mitigate any potentially adverse environmental and social impacts, a mechanism for environmental and social monitoring as well as a guideline for capacity The World Bank RESTRUCTURING ISDS Low Income Community Housing Support Project (P130710) enhancement. PKSF, following the project EMF, developed an abbreviated EMF for managing environmental issues associated with the household based housing structure development and renovation by borrowers of housing loans. The EMF included mitigation measures, environmental enhancement measures and a list of relevant environmental codes of practices for constructions/civil works to avert negative impacts and strengthen positive outcomes of the selected interventions. The Environmental Management Plan (EMP) to be generated for the sub-projects adopted a mechanism to incorporate the cost of mitigation measures into the project budget. In addition, the EMF has provided a negative list of attributes so that no natural habitats or physical cultural resources will be affected during the implementation of slum upgrading interventions. In general, the EMF will ensure environmental management of all interventions as well as compliance with the Bank's Safeguard policies. The SMF provides guidelines for all inclusive participatory identifiation and design of settlement upgrading subprojects. Site specific EMPs and SMPs have been agreed with the Bank for 10 communities and followed in subproject cycle, while drafts are ready for remaining 7 as of proposed restructuring. Project SEA/SH risks have been assessed to be low using the online tool and the project GRM is being strengthened for managing SEA/SH risks or any incidents going forward. Performance Standards for Private Sector No Activities OP/BP 4.03 It is highly unlikely that any natural habitats formed largely by native plant and animal species would undergo transformation of use or would be affected or modified by project activities. It is obvious that the project will not implement any Natural Habitats (OP) (BP 4.04) Yes activities inside the Protected Areas (Wildlife Sanctuaries, National Parks, etc.). As settlements or communities to be upgraded in the sub-urban areas of Comilla, Narayanganj, and Sirajganj are not fully identified or details of sub-project activities and The World Bank RESTRUCTURING ISDS Low Income Community Housing Support Project (P130710) interventions that may have environmental impacts are not yet available, the Natural Habitat OP has been triggered as a precautionary measure. However, the EMF has included a negative list of attributes to avoid implementing interventions in the natural habitats. In addition, the presence of natural habitats will be assessed during the environmental screening of sub-projects. Environmental screening of all sites has been initiated and project activities in none of them affected natural habitats. Forests (OP) (BP 4.36) No Pest Management (OP 4.09) No Although the project sites/communities being upgraded were not fully identified at appraisal, it was highly unlikely that the design and implementation of slum upgrading interventions may affect, modify, or reverse any designated physical cultural resources located in the project secondary towns. Since the LICHSP implements basic infrastructure and services including affordable housing for urban poor, OP 4.11 (Physical Cultural Resources) has been triggered and the impacts are being examined as part of the environmental screening/ assessment of each sub- Physical Cultural Resources (OP) (BP 4.11) Yes project when a particular site is selected for upgrading. The ‘Chance find’ procedures conforming to local applicable legislation on heritage are evaluated when such sites are identified during the design phase or during the actual construction period and the related activity will not be eligible for financing under the project. However, the EMF has included a negative list of attributes to avoid impacting designated physical cultural resources or heritage sites. Environmental screening of all sites has been initiated and project activities in none of them affected any physical cultural resources. The project covers the urban centers only. The slum areas are developed largely on vacant public lands and there is no likelihood of impacts on areas Indigenous Peoples (OP) (BP 4.10) No inhabited by ethnic minorities or tribal peoples. None of the subproject sites has presence of commuities of indigeneous status. The World Bank RESTRUCTURING ISDS Low Income Community Housing Support Project (P130710) The project is developing community-based upgrading plans where tenure is secured, either on site, or through voluntary relocation to sites identified and secured for settlement upgrading under the project. All on site development are being done in a voluntary community participation method, and without a view to displace anyone. Temporary relocation to allow land development and civil works construction have occured in only one site in Sirajganj as of restructuring. Displacement of people for infrastructure development have been avoided to the extent feasible. In unavoidable circumstances, few households may need to shift their houses to allow civil works in road, walkway, drainage, etc. Resumption of public land may also be required at critical circumstances. The Project’s involuntary resettlement issues can be identified only when a Involuntary Resettlement (OP) (BP 4.12) Yes particular site is selected for construction and screened for social safeguard compliance. NHA has, therefore developed the Social Management Framework (SMF) in compliance with the Bank’s OP 4.12 to address social safeguard and other issues arising at project implementation stage and to ensure social inclusion in the process. The SMF guides NHA to assess social impacts, and prepare Social Management Plans (SMP) including Resettlement Action Plans (RAP) in compliance with the Bank policy on social safeguards. None of the subproject sites involved involuntary resettlement including physical or economic displacement. Physical relocation of households was managemed through voluntary temporatary relocation by the beneficiaries to facilitate land development and reblocking in Kobdaspara in Sirajganj City and managed under SMP. No RAP was therefore prepared. Safety of Dams (OP) (BP 4.37) No Projects on International Waterways (OP) No (BP 7.50) Projects in Disputed Areas (OP) (BP 7.60) No KEY_POLICY_TABLE II. KEY SAFEGUARD POLICY ISSUES AND THEIR MANAGEMENT The World Bank RESTRUCTURING ISDS Low Income Community Housing Support Project (P130710) A. SUMMARY OF KEY SAFEGUARD ISSUES 1. Describe any safeguard issues and impacts associated with the Restructured project. Identify and describe any potential large scale, significant and/or irreversible impacts. The investment activities under the project for improvement of basic infrastructure services and upgrading community settlement for low-income urban populations are being done through in-situ upgrading, re-blocking, land sharing and voluntary relocation approaches. In-situ upgrading and re-blocking: In situ upgrading allows communities to stay on site and improve their housing without any population displacement or acquisition of land. However, for re-blocking, some houses will have to be moved partially or entirely to allow space for the infrastructure. Displacement of people for infrastructure development will be avoided to the extent feasible. In unavoidable circumstances, few households may need to shift their houses to allow civil works in road, walkway, drainage, etc. Land sharing: Land sharing will be adopted when an agreement is reached between slum dwellers and land owners (preferably public lands) that the slum dwellers will vacate all but a portion of the land (usually the least economically viable) in exchange for some form of right to stay on location. This will allow slum dwellers to remain in their local communities, and usually close to economic opportunities. The community and concerned households will voluntarily vacate all but a portion of the land for the land owner(s) in exchange for some form of right to stay on the location. The physical structures will be relocated and pushed back into the land portion allowed for them to stay. Some of the households and other physical establishments will be relocated temporarily for the construction period. Voluntary relocation: Communities on environmentally vulnerable areas and on lands with no options to secure tenure on site, voluntary relocation and rehabilitation of community is an option for community upgrading. The communities will arrange the land through direct purchase, lease or manage through voluntary donation. The NHA may also arrange the land through involuntary acquisition, direct purchase or inter-ministerial transfer and lease out to the communities on long-term basis. This option will not involve involuntary resettlement. Should land acquisition trigger involuntary displacement of people. Involuntary acquisition of land is not expected and has been avoided so far. Any involuntary acquisition of land is managed under the legal instrument, “The Acquisition and Requisition of Immovable Property Act, 2017� replacing the earlier law “The Acquisition and Requisition of Immovable Property Ordinance, 1982� on 21 September 2017. In all cases, where involuntary displacement of people and acquisition of land are involved, the World Bank Operational Policies on Involuntary Resettlement (OP 4.12) will trigger and compensation and resettlement of affected persons will be resorted to. The NHA has developed the Social Management Framework (SMF) that provides guidance for social screening, impact assessment and management tools for settlement upgrading subprojects. Irrespective to slum upgrading model mentioned above, the LICHSP does not expect potential large scale, significant or irreversible adverse environmental and social impacts considering the scale and magnitude of infrastructure investments. While the project is designed to improve living condition of urban poor, some minor environmental impacts have been envisaged from small-scale infrastructure works. Most infrastructures will take place in their original space or alignments where primary focus will be on-site and community managed small scale infrastructure. Therefore, the project is classified as a “Category B� under OP/BP 4.01 with a partial assessment as the ramifications are likely to be insignificant, site specific with no irreversible impacts and mitigation measures can be designed more readily. The environmental safeguard policies triggered in the LICHSP are Environmental Assessment (OP4.01), The World Bank RESTRUCTURING ISDS Low Income Community Housing Support Project (P130710) Physical and Cultural Resources (OP 4.11). However, as a precaution, Natural Habitats (OP/BP 4.04) has also been triggered. The NHA has developed an Environmental Management Framework (EMF) that provides environmental screening tools and guidelines to identify potential environmental impacts and procedures to mitigate any potentially adverse environmental impacts. The EMF includes a negative list of attributes in order to avoid damage or irreversible negative impacts on the environment. The main principle to be followed for selection of slums in LICHSP is “no slums or communities located in the environmentally sensitive areas or no sub-project interventions with significant and long- term environmental impacts will be recommended for implementation. Given the nature of the project, the level of development in most of the participating communities is such that the project will not engage in construction or expansion works related to sanitary landfills, large scale water and wastewater treatment plants, river rehabilitation through river training or large scale embankment construction that may affect the natural flow. The NHA maintains a database for sub-project specific environmental screening/assessment, EMPs and implementation monitoring of EMPs. The project M&E system captures that information as well. An independent (third party) environmental audit will be carried out to assess and evaluate the quality of environmental compliance of the construction related subprojects. Most shelter lending is being done with a view to improve, expand or construct through self-build processes, and large scale, significant or irreversible adverse environmental and social impacts are also not identified or expected. In the pilot towns, NHA will be responsible for all construction supervision and environmental and social screening for housing construction, to ensure compliance with environmental and social safeguard policies. Outside of these areas, no construction and settlement upgrading is being done or expected, although some housing upgrades and construction are being financed through individual housing loans. In these areas, PKSF ensures environmental and social screening in line with the EMF and SMF. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area. No potential indirect and/or long term impacts are anticipated as a result of the project. As communities to be upgraded are not fully identified or details of new activities or sub-projects were not available at appraisal, a framework approach has been adopted and an EMF and SMF have been developed in consultation with concerned community and local stakeholders that provides procedures to mitigate any potential adverse impacts, a mechanism for environmental and social assessments and monitoring as well as a guideline for capacity enhancement. The EMF included a negative list of activities and interventions which are not eligible for project financing, to avoid potential indirect and/or long term impacts due to project interventions. 3. Describe any potential alternatives (if relevant) considered to help avoid or minimize adverse impacts. The EMF has provided provisions for alternative analysis in terms of design and location. The steps to be followed in subproject specific alternative analysis are: (a) identify and define alternatives; (b) analyze or evaluate from environmental perspective; and (c) primarily select the locally preferred and environmentally viable alternative. The environmental management process including Environmental Mitigation Measures and Code of Practices (ECoPs) will help to consider the alternative options to avoid or minimize adverse impacts at the planning stage. 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 World Bank RESTRUCTURING ISDS Low Income Community Housing Support Project (P130710) The NHA has adopted a Social Management Framework (SMF) and an Environmental Management Framework (EMF) to address social and environmental safeguards issues that may arise during the planning, implementation, and operation of LICHSP interventions. The National Housing Authority (NHA) under the Ministry of Housing and Public Works (MoHPW) is the implementing agency of this project for all components related to civil works. This represents their first project with the World Bank. For this reason, significant capacity building was needed to orient staff to Bank procedures, and to better familiarize the Ministry with Bank-supported operations including compliance with social and environmental safeguards. As guided by the SMF and EMF, the NHA will ensure inclusion, community participation, transparency, and social accountability in the project cycle. A Project Management Unit (PMU) has been set up at NHA for identification, design and construction of infrastructure with participation from the selected communities. A Municipal Committee at the city level will be established comprising of representatives from the NHA, City Corporation or Pourashava, LGED and/or DPHE, and the communities. During implementation, Urban Resource Centers (URC) will be established in each town under the project for technical assistance to selected communities in subproject cycle. While the PMU has engaged a Social Development Specialist for management of social issues, and an Environmental Specialist, as per the requirement of the SMF and EMF, to ensure that LICHSP interventions with significant negative impacts are not selected and due diligence to relevant national laws of Bangladesh and IDA’s safeguard policies are given throughout the implementation period. NHA is responsible for all safeguards compliance in its project areas. Outside of these areas, minor home repairs or small scale construction are guided by the EMF and screened by the Partners Organizations (POs) of PKSF. Since the POs do not have experience in dealing with environmental safeguards, PKSF has developed a Credit Line Operations Manual and assigned a safeguards focal person to ensure due diligence to the Government and IDA’s safeguard policies by the POs to be involved in the housing program. 5. Identify the key stakeholders and describe the mechanism for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. Identification, design and civil works construction for community upgrading will be all inclusive and participatory. The project will involve all social groups including women, vulnerable communities and tribal peoples. NHA will hold consultations on social and environmental safeguards at all stages of implementation of the project. Public consultations with all stakeholders, at all stages of project implementation, will be carried out and the nature and number of consultation, location, and type of participants and the summary of findings will be documented. In addition to national government agencies, key stakeholders will be consulted include affected communities, community organizations, NGOs, local elected representatives, host communities, city corporations and municipalities, Local Government and Engineering Department (LGED), Department of Public Health Engineering (DPHE) and relevant private sector agencies. DISCLOSURE_TABLE B. DISCLOSURE REQUIREMENTS ENV_TABLE Environmental Assessment/Audit/Management Plan/Other Date of receipt by the Bank Date of submission for disclosure 22-May-2014 26-Aug-2014 For Category ‘A’ projects, date of distributing the Executive Summary of the EA to the Executive Directors The World Bank RESTRUCTURING ISDS Low Income Community Housing Support Project (P130710) “In country� Disclosure Country Date of Disclosure Bangladesh 17-Aug-2014 Comments RESETTLE_TABLE Resettlement Action Plan/Framework Policy Process Date of receipt by the Bank Date of submission for disclosure 22-May-2014 26-Aug-2014 “In country� Disclosure Country Date of Disclosure Bangladesh 17-Aug-2014 Comments COMPLIANCE_TABLE C. COMPLIANCE MONITORING INDICATORS AT THE CORPORATE LEVEL EA_TABLE OP/BP/GP 4.01 - Environment Assessment Does the project require a stand-alone EA (including EMP) report? Yes If yes, then did the Regional Environment Unit or Practice Manager (PM) review Yes and approve the EA report? Are the cost and the accountabilities for the EMP incorporated in the credit/loan? Yes NH_TABLE OP/BP 4.04 - Natural Habitats PCR_TABLE OP/BP 4.11 - Physical Cultural Resources Does the EA include adequate measures related to cultural property? Yes The World Bank RESTRUCTURING ISDS Low Income Community Housing Support Project (P130710) Does the credit/loan incorporate mechanisms to mitigate the potential adverse Yes impacts on cultural property? IR_TABLE OP/BP 4.12 - Involuntary Resettlement Has a resettlement plan/abbreviated plan/policy framework/process framework Yes (as appropriate) been prepared? If yes, then did the Regional unit responsible for safeguards or Practice Manager Yes review the plan? Is physical displacement/relocation expected? No Is economic displacement expected? (loss of assets or access to assets that leads No to loss of income sources or other means of livelihoods) PDI_TABLE The World Bank Policy on Disclosure of Information Have relevant safeguard policies documents been sent to the World Bank for Yes disclosure? Have relevant documents been disclosed in-country in a public place in a form and language that are understandable and accessible to project-affected groups Yes and local NGOs? ALL_TABLE All Safeguard Policies Have satisfactory calendar, budget and clear institutional responsibilities been Yes prepared for the implementation of measures related to safeguard policies? Have costs related to safeguard policy measures been included in the project Yes cost? Does the Monitoring and Evaluation system of the project include the monitoring Yes of safeguard impacts and measures related to safeguard policies? Have satisfactory implementation arrangements been agreed with the borrower Yes and the same been adequately reflected in the project legal documents? III. APPROVALS The World Bank RESTRUCTURING ISDS Low Income Community Housing Support Project (P130710) Sonya M. Sultan Task Team Leader(s) Sabah Moyeen Approved By Safeguards Advisor Practice Manager/Manager .