INTEGRATED SAFEGUARDS DATA SHEET APPRAISAL STAGE Report No.: ISDSA2422 Date ISDS Prepared/Updated: 7-Dec-2013 I. BASIC INFORMATION 1. Basic Project Data Country: Africa Project ID: P131323/P131353 Project Name: Senegal River Basin Multi-Purpose Water Resources Development Project 2 (P131323); Senegal River Basin Climate Change Resilience Development Project (P131353) Task Team Leader: Shelley Mcmillan Estimated Appraisal 14-Sept-2013 Estimated Board 4-Dec-2013 Date: Date: Managing Unit: AFTN2 Lending Instrument: Investment Project Financing GEF Focal Area: Multi-focal area Sector(s): General water, sanitation and flood protection sector (30%), Irrigation and drainage (25%), Health (20%), General agriculture, fishing and forestry sector (15%), General public administration sector (10%) Theme(s): Water resource management (40%), Regional integration (30%), Malaria (15%), Climate change (10%), Gender (5%) Is this project processed under OP 8.50 (Emergency Recovery) or OP 8.00 No (Rapid Response to Crises and Emergencies)? Project Financing Data (in USD Million) Total Project Cost: 240.50 Total Bank Financing: 221.50 Total Cofinancing: Financing Gap: 0.00 Financing Source Amount BORROWER/RECIPIENT 12.00 International Development Association (IDA) 212.50 IDA Grant 0.00 Global Environment Facility (GEF) 4.00 Least Developed Countries TF for Climate Change Activities 12.00 Total 240.50 Environmental A - Full Assessment Category: Is this a Repeater No project? Is this a Transferred No project? 2. Project Development Objective(s) / Global Environmental Objective(s) A. Project Development Objective(s) The overall Program Development Objective is: to enhance regional integration among the riparian countries of the Senegal River Basin through OMVS for multi-purpose water resources development to foster improved community livelihoods. The MWRD2 Project Development Objective is: to improve coordinated management of water resources for socially, environmentally and economically sustainable development in the Senegal River Basin. Responding to the needs of OMVS and the riparian states, MWRD2 will have broadly similar components to MWRD1 as follows: (i) consolidating and further strengthening the institutional, legal and technical framework of the Senegal River Basin to better serve all four riparian countries, (ii) expanding the scope and coverage of concrete water resources development activities at the local level that generate significant income to reduce poverty, and (iii) supporting water resources development and planning, both by developing and maintaining water infrastructure, and in supporting future planning within the basin. MWRD2 activities will primarily be located in the priority zones defined by studies in MWRD1. Each component will scale-up activities started under MWRD1, incorporating lessons learnt and taking forward successful elements for further development. Climate resilience will also be strengthened through the activities supported by GEF funding. B. Global Environmental Objective(s) Strengthen trans-boundary water resources management in the Senegal River Basin including climate change adaptation and implementation of priority actions of the Strategic Action Plan. 3. Project Description Overview of the program design: The project design aims to simultaneously increase the productive uses of water and enable macro-economic growth while safeguarding the health and livelihoods of vulnerable communities in the river basin. The regional integration process establishes the inter-related parameters for sustainable water resources development across all sectors and the project components provide mutually reinforcing interventions at regional, local and national levels. Specifically, MWRD2 will support the update the partition of costs; improve the knowledge base in the Senegal River Basin; and build capacity at OMVS, national cellules, national executing agencies and local community organizations for sustainable management of water infrastructure. MWRD2 will also support interventions to raise household income, safeguard the existing hydropower supply through essential maintenance works and build a pipeline of water infrastructure investments for future financing. With GEF financing, climate resilience in the Senegal River Basin will be improved. Building on the achievements from MWRD1, support will be provided under MWRD2 to initiate fisheries activities in Guinea and scale-up in the remaining states, incorporating new elements of aquaculture. MWRD2 will continue to address the public health risks from water related diseases, incorporating treatment for new NTDs. The treatment of the 5 critical NTDs will be incorporated into the health sub-component of the project. In addition, the project will continue to contribute to achievement of universal LLIN coverage and improved malaria control in the river basin. Following the increased and visible impacts of climate change, MWRD2 also incorporates additional measures to improve planning for climate resilience in the future. The focus for increasing resilience to climate risks is on improving the knowledge base and future planning including identifying the climate resilience needs, how these should be factored into future planning and identifying methods to make local livelihoods more climate resilient. Resilience to climate risks is supported through improved monitoring of flows; an update of the water resources model to take into account climate variability; and piloting projects for climate resilience. MWRD2 builds on several regional to local level experiences in addition to consolidating thirty years of cooperation and joint development in the Senegal River Basin, including; (i) the successful completion of MWRD1; (ii) the development of jointly-owned energy infrastructure in the Manantali and Diama dams; (iii) the Inclusive Framework that encouraged the full involvement of Guinea in the joint management of the Senegal River Basin; (iv) the GEF-funded Senegal River Basin Water and Environmental Management Project which laid the foundation for more integrated land, water and environmental management in the Basin; (v) the ongoing Felou Hydropower Project; and (vi) the Bank’s current and previous experience internationally in transboundary river basins. MWRD2 is also closely linked to the national sector level interventions in the member states, especially the agriculture interventions. In Mali, Mauritania and Senegal the project will coordinate with the Sahel and West Africa World Bank/GEF Program in support of the Great Green Wall Initiative. Lessons and experiences from the above, coupled with the Bank’s long standing involvement in the Senegal River Basin, clearly demonstrate that regional integration fosters more effective sustainable development and multi-sectoral investments. Therefore, the Project provides a unique comparative advantage to mainstream close collaboration between institutions working on water resources management of the Senegal River Basin at regional, national and local levels while consolidating donor interventions through a coherent framework of actions. A. Project Components The project will have three inter-related components supporting the project development objective: (1) Institutional development; (2) Multi-purpose water resources development and (3) Infrastructure management and planning. Component 1: Institutional Development (USD$19.11 million) The overall objective of Component 1 is to build capacity for cooperative management. This first component will support both institutional development and project implementation through the following sub-components: (a) 1.1 - Updating the Inclusive Framework and strengthening the role of Guinea within OMVS (b) 1.2 - Modernizing and reinforcing the institutional capacities of OMVS and related agencies (c) 1.3 - Strengthening the capacity of OMVS and national agencies to lead climate adaptation efforts in the region [GEF funded] (d) 1.4 - Strategic management of the project Component 2: Multi-Purpose Water Resources Development (USD$174.23 million) The overall objective of this component is to promote income-generating activities and to improve livelihoods for the basin population. This component includes a number of core multi-sectoral activities related to the development of water resources in some sub-basins. Sub-components are: (a) 2.1 - Hydro-agricultural development and water resources protection (b) 2.2 - Sustainable fisheries management and aquaculture (c) 2.3 - Reduction of the incidence of water-borne diseases (d) 2.4 - Pilot Approaches to improve climate resilience [GEF funded] Component 3: Infrastructure Management and Planning (USD$29.62 million) 68. The overall objective of Component 3 is to advance climate resilient water resources planning and development in the region. There are three main sub-components: (a) 3.1 - Dam management and hydropower development (b) 3.2 - Planning for climate resilience (c) 3.3 - Development of navigation along the Senegal River Basin Project Financing Project financing in the amount of US$212.5 million will be provided by IDA and US$16 million provided from the GEF and LDCF (Least Developed Countries Fund). Counterpart funding of US$12 million will be provided to support the implementation of discrete activities which are high priorities for member states. As such, and as agreed with member states, the counterpart funding is allocated to increase the coverage of interventions to reduce the incidence of water-related diseases, development of sustainable fisheries and aquaculture, in addition to some project management costs. In line with OMVS and member state priorities, approximately 40% of the IDA financing will go towards infrastructure; around 20% to design and supervision; approximately 20% to institutional strengthening; and approximately 20% to the purchase of goods and equipment. At mid-term, the project will assess the extent to which activities are adequately implemented and make needed adjustments. OMVS has previous experience working with the GEF and the activities supported by GEF/LDCF will build upon previous engagement and will be complementary to the IDA-funded activities. The Dutch Government is planning to finance a parallel project to MWRD2 with OMVS. Proposed activities include addressing the problems of invasive aquatic species and support for water users associations. The Agence Française de Développement (AFD) has also expressed interest to provide parallel financing to support OMVS in activities related to further development of the Schéma d'Aménagement et de Gestion des Eaux (Comprehensive Senegal River Basin Master Plan - SDAGE), such as development of country level planning tools and for sanitation improvements in the basin. 4. Project location and salient physical characteristics relevant to the safeguard analysis (if known) The proposed Project involves all the riparian countries (Guinea, Mali, Mauritania and Senegal) of the Senegal River basin. The Senegal River basin covers a surface area of about 300,000 km2. The high plateau in northern Guinea represent 31,000 km2 (11 percent of the basin), 155,000 km2 are situated in western Mali (53 percent of the basin), 75,500 km2 are in southern Mauritania (26 percent of the basin) and 27,500 km2 are in northern Senegal (10 percent of the basin). The basin has three distinct parts: the upper basin, which is mountainous, the valley (itself divided into high, middle and lower) and the delta, which is a source of biological diversity and wetlands. Topographical, hydrographic and climatic conditions are very different in these three regions and seasonal temperature variations are extensive. 5. Environmental and Social Safeguards Specialists on the Team Robert A. Robelus ( AFTA1 ) Salamata Bal ( AFTCS ) 6. Safeguard Policies Triggered? Explanation (Optional) Environmental Assessment OP/BP Yes The MWRD2 involves a significant number of 4.01 construction and environmental and social management activities related to the sub-projects. These subprojects cover rehabilitation of irrigated areas for rice production and vegetable farming for women groups, a health component financing pesticide impregnated mosquito nets and medicines to control 5 neglected tropical diseases, including Schistosomiasis and an inland small-scale fisheries component. The environmental and social management activities of the fisheries and irrigation sub-components include environmental and social management actions, which also would trigger OP/BP 4.01. An evaluation will be carried out with regard to the environmental and social dimensions of the Balassa dam. An Environmental and Social Advisory Panel will be established to provide advice on the TORs and environmental and social studies to be carried out. MWRD2 has prepared an ESIA, instead of an ESMF, since most sub-projects have already been identified. Natural Habitats OP/BP 4.04 Yes Stocking of natural water bodies with indigenous fish species might be one of the sub-project activities. This activity could upset the natural balance in existing fish stocks if not done according ecological principles. This potential activity triggers OP/BP 4.04 and is addressed in the ESIA. Forests OP/BP 4.36 Yes OP/BP 4.36 is triggered by the reforestation activities carried out in the Fouta Djallon, a very sensitive ecological area in the headwaters of the Senegal River, which has been and is subject to significant deforestation as a consequence of agricultural expansion. The ESIA includes measures for addressing the reforestation activities. Pest Management OP 4.09 Yes The Pest and Pesticide Management Plan (PPMP) was not implemented under MWRD1, since there was no production in the rehabilitated irrigation systems. Presently the rehabilitation is being finalized and production will start during the implementation of MWRD2. The updated PPMP will be implemented during MWRD2. Intensification of irrigated agricultural production, as envisaged during MWRD2 might increase the use of pesticides and chemical fertilizers. The implementation of the updated PPMP will mitigate the health and environmental impacts of the increased use of pesticides and chemical fertilizers. MWRD2 will not finance the procurement of pesticides. Physical Cultural Resources OP/BP Yes OP/BP 4.11 is triggered by the feasibility 4.11 studies for the new Balassa dam and by the construction activities associated with the sub-projects. An archaeological survey will be carried out in the reservoir and dam areas for the new dam. This is addressed in the ESIA; a Chance Find Procedure will be included in all Contractor Contracts. Indigenous Peoples OP/BP 4.10 No There are no indigenous people in the Senegal River Basin as defined by OP/BP 4.10. Involuntary Resettlement OP/BP 4.12 Yes No physical resettlement is anticipated due to the nature of the intended rehabilitation works to be carried out under the various sub-projects. There might be a need to compensate for the loss of crops, trees or property caused by the rehabilitation of the irrigation schemes. The lack of definition around specific subprojects will be addressed through the preparation and disclosure of the updated Resettlement Policy Framework (RPF). OP/BP 4.12 might be potentially triggered as a consequence of the restriction of access to certain fishing grounds needed as spawning areas, temporary closure of fishing areas for biological recovery of fish stocks. It is not yet certain that these activities will be carried out. In case OP/BP 4.12 will be triggered a Process Framework (PF) will be prepared, disclosed and implemented. Any sub-project, including construction, can only start if Project Affected People (PAPs) have been compensated in compliance with OP/BP 4.12. The eventual RAPs or PFs prepared for subprojects will need to be cleared by the Bank and consulted upon with stakeholders. These RAPs and PFs also will be disclosed in-country and in the World Bank’s Infoshop prior to the start of any subproject construction activity. Safety of Dams OP/BP 4.37 Yes OP/BP 4.37 is triggered by the feasibility and environmental and social studies for the new Balassa dam. This policy is also triggered by the fact that the irrigated agricultural subprojects are dependent for their water from the Manantali and Diama Dams. The dam safety reports for the Manantali and Diama Dams have been recently reviewed by the World Bank and no dam safety issues have been identified. A Dam Safety Advisory Panel will be established to manage the dam safety aspects of the MWRD2. Projects on International Waterways Yes The governments of the four riparian countries OP/BP 7.50 were notified of the Project through the OMVS, in which all four countries are represented. A letter regarding this notification has been sent to the Bank. Projects in Disputed Areas OP/BP 7.60 No There are no Disputed Areas in the Senegal River Basin. Therefore OP/BP 7.60 is not triggered. OMVS has the mandate to implement and manage sub-projects in the Senegal River Basin with the support of the four riparian countries. II. Key Safeguard Policy Issues and Their Management A. Summary of Key Safeguard Issues 1. Describe any safeguard issues and impacts associated with the Restructured project. Identify and describe any potential large scale, significant and/or irreversible impacts: The program (MWRD1 and MWRD2) is classified as category A in the Environmental Assessment classification of the World Bank, the main reason being that MWRD2 finances preparatory studies for Balassa dam and rehabilitation for Diama dam in the Senegal River Basin. An independent dam safety panel will be formed to review these studies and the works at Diama dam. The TORs will be prepared before project effectiveness. MWRD2 covers a similar range of activities as MWRD1 over an extended geographical area, the Senegal River Basin in four countries, and therefore requires a substantive level of due diligence. The table above gives details on the safeguards issues associated with the project. MWRD2 sub-projects: rehabilitation of irrigation schemes, health component and fisheries and aquaculture component will have very limited environmental and social impacts, similar in nature as the impacts under MWRD1. These impacts and mitigation measures have been described in the ESIA prepared for MWRD2. MWRD2 will also finance the rehabilitation of existing or development of new small-scale fish farms and hatcheries for the production of juvenile fish, which will be used to stock natural water bodies. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area: N/A 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. N/A 4. Describe measures taken by the borrower to address safeguard policy issues. Provide an assessment of borrower capacity to plan and implement the measures described. The capacity of OMVS and the member states for environmental and social management has been strengthened under the Senegal River Basin Water and Environmental Management GEF Project and even more so under the MWRD1 project. This included building a core group of transboundary environmental management expertise. During the preparation of MWRD1, OMVS prepared an Environmental and Social Management Framework (ESMF), a Resettlement Policy Framework (RPF) and a Pest and Pesticide Management Plan (PPMP) in compliance with the requirements of the World Bank Safeguard Policies. These instruments have been reviewed and updated for use in MWRD2. MWRD2 has prepared an ESIA, instead of an ESMF, since the most of the project activities to be financed are known. The RPF and PPMP have been updated. The updated ESIA, PPMP and RPF have been consulted upon and disclosed in-country and at the Infoshop prior to appraisal. At the start of the implementation of MWRD1, the ESMF was used to screen all sub-projects. The majority of sub-projects were found to pose very low environmental and social risks, mostly related to environmental and social management during construction. One of the reasons for this low risk was that irrigated agriculture sub-projects involved rehabilitation of irrigation systems rather than new construction. For these low risk sub-projects only an Environmental and Social Management Plan (ESMP) was prepared and implemented, which was based on the ESMP in the ESMF. An Environmental and Social Impact Assessment (ESIA) was only prepared and implemented for those sub-projects with potentially high impacts. The only sub-project for which a specific ESIA and associated ESMP and a Resettlement Action Plan (RAP) were prepared and implemented was the construction of the Krankaye canal, a new main irrigation water supply canal, in the Senegal River Delta. The Krankaye sub-project did not physically displace any households, but did have an impact on property. Project Affected People (PAPs) have been compensated in compliance with OP/BP 4.12. Community level measures taken to mitigate or compensate for impacts in the Krankaye sub-project included flood protection, foot bridges for continued access to irrigation schemes at the other side of the canal and a siphon to continue to supply water to private irrigated areas. None of the other sub-projects triggered OP 4.12. The various ESMPs for sub-projects included a wide range of mitigation measures. These mitigation measures included among others social compensation measures, for example the construction of laundry and bathing areas, ramps for cattle to have access to water, foot bridges to provide access to irrigation areas and so on. All the ESMPs included construction related environmental and social management measures, including prevention and management of hydrocarbon spills and health and safety measures during construction. Component specific measures were also taken, for example improving hygiene and solid waste management at the new fish markets financed under MWRD1. The Pest and Pesticide Management Plan (PPMP) was not implemented during MWRD1, since the rehabilitation of all the irrigation systems financed under MWRD1 is only now being finalized. There was no increased agricultural production under MWRD1. The updated PPMP will be implemented under MWRD2. MWRD2 has prepared an ESIA, since most sub-projects have already been defined, and updated the RPF and the PPMP from MWRD1. It is not expected that OP 4.12 will be triggered during the implementation of MWRD2, but if there is any involuntary resettlement, a RAP will be prepared, consulted upon, and disclosed in-country and in the World Bank Infoshop. RAPs will need to be cleared by the Bank. Construction can only start after Project Affected People (PAP) have been compensated in compliance with OP/BP 4.12. The ESIA and the RAP were consulted upon by February 2013. The ESIA and PPMP have been disclosed in-country and in the World Bank Infoshop on 26 March 2013. The RPF was finalized and cleared for disclosure on 10 June 2013. These instruments will be implemented and monitored by the Safeguard Specialist at the PCU as was done for MWRD1. Executing agencies will also be responsible for implementing and monitoring safeguards for specific activities and for oversight of contractors. The main area of institutional support, which OMVS will require during the implementation of MWRD2 is in advancing the feasibility studies of the new Balassa dam and the evaluation of the environmental and social dimensions of this new dam. It has been agreed with OMVS that a Dam Safety and an Environmental and Social Advisory panel will be established as needed, so that the panel can provide advice on the TORs for the feasibility studies and the environmental and social studies and on these studies themselves. The TOR for the ESIA of the new dam will need to be cleared by the Bank’s Regional Safeguard Coordinator for the Africa Region. There are no other environmental and social risks, which are outside the scope of the World Bank’s safeguard policies. 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. The principal stakeholders of this Project are identifiable at three levels-regional, national, and local: The regional stakeholders are the institutions involved in managing the Senegal River (the OMVS) and its infrastructure (SOGENAV, SOGEM and SOGED). These stakeholders have defined the project in discussion with national counterparts. Nationally, the principal stakeholders are the four national governments and the four national OMVS cellules. Through performance management contracts, four executing agencies: Société d’Aménagement des Terres du Delta (SAED, Senegal), Société Nationale de Développement Rural (SONADER, Mauritania), Direction Nationale du Génie Rural (DNGR, Guinea), and L'Agence de Developpement Rural de la Vallee du fleuve Sénégal (ADRS, Mali) will implement the agriculture and related sub-components. It is important to note that all four governments have endorsed the Project. OMVS has demonstrated a continued interest in applying a participatory approach to the Project design. National Project Planning Committees (NPPCs) were established in each riparian country and these committees have participated actively in Project preparation. National officials also provide continual assistance and participate in national and regional workshops, steering committees and other stakeholder consultations during project preparation. At the local level, the stakeholders include the local government, local decision-makers, rural communities, women’s groups, and schools. Local level consultations were held by OMVS in December 2012 for all locally implemented activities; including fisheries improvements, agroforestry, river bank protection and development or rehabilitation of irrigated areas. Meetings were held in each zone of intervention and facilitated by local committees. Photographs and meeting records were provided by OMVS. B. Disclosure Requirements Environmental Assessment/Audit/Management Plan/Other Was the document disclosed prior to appraisal? Yes Date of receipt by the Bank 18-Mar-2013 Date of submission to InfoShop 26-Mar-2013 For category A projects, date of distributing the Executive Summary of 23-Apr-2013 the EA to the Executive Directors "In country" Disclosure Guinea 28-Feb-2013 Comment: Mali 28-Feb-2013 Comment: Mauritania 28-Feb-2013 Comment: 28-Feb-2013 Comment: Resettlement Action Plan/Framework/Policy Process Was the document disclosed prior to appraisal? Yes Date of receipt by the Bank 28-Mar-2013 Date of submission to InfoShop 14-Jun-2013 "In country" Disclosure Guinea 28-Feb-2013 Comments: Mali 28-Feb-2013 Comments: Mauritania 28-Feb-2013 Comments: Senegal 28-Feb-2013 Comments: Pest Management Plan Was the document disclosed prior to appraisal? Yes Date of receipt by the Bank 18-Mar-2013 Date of submission to InfoShop 26-Mar-2013 "In country" Disclosure Guinea 28-Feb-2013 Comments: Mali 28-Feb-2013 Comments: Mauritania 28-Feb-2013 Comments: Senegal 28-Feb-2013 Comments: If the project triggers the Pest Management and/or Physical Cultural Resources policies, the respective issues are to be addressed and disclosed as part of the Environmental Assessment/Audit/or EMP. If in-country disclosure of any of the above documents is not expected, please explain why: 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 [ X ] No [ ] NA [ ] report? If yes, then did the Regional Environment Unit or Sector Yes [ X ] No [ ] NA [ ] Manager (SM) review and approve the EA report? Are the cost and the accountabilities for the EMP incorporated Yes [ X ] No [ ] NA [ ] in the credit/loan? OP/BP 4.04 - Natural Habitats Would the project result in any significant conversion or Yes [ ] No [X ] NA [ ] degradation of critical natural habitats? If the project would result in significant conversion or Yes [ ] No [X ] NA [ ] degradation of other (non-critical) natural habitats, does the project include mitigation measures acceptable to the Bank? OP 4.09 - Pest Management Does the EA adequately address the pest management issues? Yes [ ] No [ X] NA [ ] Is a separate PMP required? Yes [X ] No [ ] NA [ ] If yes, has the PMP been reviewed and approved by a Yes [X ] No [ ] NA [ ] safeguards specialist or SM? Are PMP requirements included in project design?If yes, does the project team include a Pest Management Specialist? OP/BP 4.11 - Physical Cultural Resources Does the EA include adequate measures related to cultural Yes [ X ] No [ ] NA [ ] property? Does the credit/loan incorporate mechanisms to mitigate the Yes [ ] No [ ] NA [ X ] potential adverse impacts on cultural property? OP/BP 4.12 - Involuntary Resettlement Has a resettlement plan/abbreviated plan/policy Yes [ X ] No [ ] NA [ ] framework/process framework (as appropriate) been prepared? If yes, then did the Regional unit responsible for safeguards or Yes [ X ] 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 [ X ] and constraints been carried out? Does the project design include satisfactory measures to Yes [ ] No [ ] NA [ X ] overcome these constraints? Does the project finance commercial harvesting, and if so, does Yes [ ] No [ X ] NA [ ] it include provisions for certification system? OP/BP 4.37 - Safety of Dams Have dam safety plans been prepared? Yes [ ] No [ ] NA [ X ] Have the TORs as well as composition for the independent Yes [ ] No [ X ] NA [ ] Panel of Experts (POE) been reviewed and approved by the Bank? Has an Emergency Preparedness Plan (EPP) been prepared and Yes [ ] No [ ] NA [ X ] arrangements been made for public awareness and training? OP 7.50 - Projects on International Waterways Have the other riparians been notified of the project? Yes [ X ] No [ ] NA [ ] If the project falls under one of the exceptions to the notification Yes [ ] No [ ] NA [ X ] requirement, has this been cleared with the Legal Department, and the memo to the RVP prepared and sent? Has the RVP approved such an exception? Yes [ ] No [ ] NA [ X ] The World Bank Policy on Disclosure of Information Have relevant safeguard policies documents been sent to the Yes [ X ] No [ ] NA [ ] World Bank's Infoshop? Have relevant documents been disclosed in-country in a public Yes [ X ] 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 [ X ] No [ ] NA [ ] responsibilities been prepared for the implementation of measures related to safeguard policies? Have costs related to safeguard policy measures been included Yes [ X ] No [ ] NA [ ] in the project cost? Does the Monitoring and Evaluation system of the project Yes [ X ] No [ ] NA [ ] include the monitoring of safeguard impacts and measures related to safeguard policies? Have satisfactory implementation arrangements been agreed Yes [ X ] No [ ] NA [ ] with the borrower and the same been adequately reflected in the project legal documents? III. APPROVALS Task Team Leader: Name: Shelley Mcmillan Approved By: Regional Safeguards Name: Alexandra C. Berezedi Date: June 10, 2013 Advisor: Sector Manager: Name: Jonathan S. Kamkwalala Date: June 6, 2013