INTEGRATED SAFEGUARDS DATASHEET APPRAISAL STAGE I. Basic Information Date prepared/updated: 04/12/2012 Report No.: AC6605 1. Basic Project Data Country: Bangladesh Project ID: P125447 Project Name: Community Climate Change Program Task Team Leader: Yuka Makino Estimated Appraisal Date: February 13, Estimated Board Date: October 31, 2012 2012 Managing Unit: SASDI Lending Instrument: Specific Investment Loan Sector: Other social services (34%);Flood protection (33%);General agriculture, fishing and forestry sector (33%) Theme: Climate change (70%);Natural disaster management (15%);Other social protection and risk management (15%) SPF Amount (US$m): 0 GEF Amount (US$m.): 0 PCF Amount (US$m.): 0 Other financing amounts by source: Borrower 0.00 Bangladesh MDTF for Climate Change 12.50 Financing Gap 0.00 12.50 Environmental Category: B - Partial Assessment Simplified Processing Simple [] Repeater [] Is this project processed under OP 8.50 (Emergency Recovery) Yes [ ] No [ ] or OP 8.00 (Rapid Response to Crises and Emergencies) 2. Project Objectives The Development Objective of the project is to enhance the capacity of selected communities to increase their resilience to the impacts of climate change. An intermediate indicator of success will be the establishment of an effective grant financing mechanism within Palli Karma-Sahayak Foundation(PKSF) to channel funds to NGOs to fund community-based climate change adaptation activities. 3. Project Description The project will have 3 main components: (i) Community climate Change Fund (ii) Knowledge Management, Monitoring and Evaluation and Capacity Building; and (iii) Project management. Component 1. Community Climate Change Fund (US$10.40 million) This component would establish a US$10.40 million fund to finance community-based climate change adaptation projects implemented with the assistance of NGOs. The fund would be managed by PKSF through a separate Project Management Unit (PMU), to be set up and supported (including staffing, equipment, and operation costs) under Component 3. PKSF will invite project proposals from NGOs to address climate change impacts in (a) salinity affected coastal areas; (b) flood affected char-lands and river basins; and (c) drought affected or rainfall-scarce areas. Each project proposal must be located within a vulnerable zone (a list of upazilas in these zones is provided in Annex 2), and must address at least one of the following six pillars of the BCCSAP: (a) improve food security, social protection and health; (b) improve disaster management capacity; (c) climate proof existing infrastructure; (d) improve research and knowledge management to predict the likely scale and timing of climate change in different sectors; (e) explore mitigation and low-carbon development opportunities; and (f) focus on capacity building and institutional strengthening. The sub-projects would range from US$20,000 to US$1 million, and all would be completed three months before the completion date of the CCCP. The proposals would also be reviewed for social and environmental safeguards, including gender and social inclusion, as per Bank policy. Component 2. Knowledge Management, Monitoring and Evaluation, and Capacity building (US$ 0.44 million) Since community-based adaptation to climate change is an evolving field of practice, this component would promote the sharing of lessons on best practices among the participating NGOs, as well as in the wider NGO community and in regional and global forums. This component would also support a structured learning process of capturing lessons and incorporating best practices into the design and implementation of community-based interventions, including the preparation of a toolkit and guidelines, and visits to adaptation activities in different vulnerable zones. Technical assistance will be provided to develop options for institutionalizing lessons learned. This component will also (a) build the capacity of NGOs to prepare eligible community- based climate change adaptation sub-project proposals; (b) operationalize an M&E system to ensure effective monitoring of project outcomes at the project and community levels; and to enable an independent third party monitoring and impact evaluation of financial system performance, and a comprehensive review and evaluation of outcomes at project completion; and (c) establish a grievance redress system to handle any issues raised by stakeholders about the implementation of the project or any sub-project. Further details of the monitoring framework are in Annex 3. Component 3. Project Management (US$1.66 million) This component would finance technical assistance to: (a) establish a PMU within PKSF to manage the multi-donor Climate Change Resilience Fund and monitor the implementation of sub-projects. It would also finance the operating costs of the Fund, including equipment, financial management, procurement, technical assistance, and administrative expenses; and (b) build the technical capacity of PKSF to appraise sub- project proposals submitted by NGOs; and to operationalize the procedures for Fund management outlined in the Operational Manual (see Annex 3 for details). 4. Project Location and salient physical characteristics relevant to the safeguard analysis The activities will be initially focused on the climate vulnerable areas namely: (i) Salinity affected areas; (ii) Flood affected char-lands and river basins; and (iii) Drought affected or rainfall scarce areas. The target climate risk areas may be expanded upon successful implementation of the project. The target Upazilas under this project were identified based upon the degree of exposure to climate risk, and level of poverty. The project targets the following Upazilas for implementation of sub-grants. Climate Risk DistrictUpazila Drought Chuadanga Damurhuda Jessore Jhikargacha, Katwali, Chougacha, Monirampur, Sharsha Naogaon Porsha, Naogaon Sadar, Niamatpur, Patnitala Rajshahi Godagari & Tanore Satkhira Assasuni & Debhata Natore Lalpur & Natore Sadar Salinity Satkhira Shyamnagar, Kaliganj, Assasuni Khulna Dighalia, Rupsha, Dacope, Batiaghata Jessore Katwali & Jhikargacha Bagerhat Sarankhola, Morrelganj, Fakirhat Patuakhali Kalapara, Golachipa, Dashmina Barguna Amtali & Barguna Sadar Flood Barisal Babuganj Cox’s Bazar Moheskhali Jamalpur Bakshiganj, Dewanganj, Islampur, Madarganj, Melandaha Mymensingh Gauripur, Haluaghat, Iswarganj, Nandail, Phulpur Bagerhat Fakirhat Jessore Jhikargacha & Katwali Khulna Batiaghata, Dighalia, Rupsha Kurigram Char Rajibpur, Chilmari, Raumari, Ulipur Nilphamari Jaldhaka, Kishoreganj & Nilphamari Sadar The exact locations of the sub-projects to be implemented under the project cannot be determined at this stage. Physical characteristics will be known once the sub-grant proposals are received and selected for CCCP funding. But it is likely that some of the proposals may include infrastructures as a critical means for climate change adaptation and there is potential for use and/or access of private or public lands with private users. Sub-grants with infrastructure will use vacant public land to the extent feasible, and in unavoidable circumstances, will not take private land through acquisition (using power of eminent domain) but voluntary contribution or contribution against compensation collectively by the community. CCCP will also avoid financing subgrants with adaptation measures involving physical displacement of people and affecting the livelihood of communities including the tribal peoples. 5. Environmental and Social Safeguards Specialists Ms Nadia Sharmin (SASDI) Mr Md. Akhtaruzzaman (SASDS) 6. Safeguard Policies Triggered Yes No Environmental Assessment (OP/BP 4.01) X Natural Habitats (OP/BP 4.04) X Forests (OP/BP 4.36) X Pest Management (OP 4.09) X Physical Cultural Resources (OP/BP 4.11) X Indigenous Peoples (OP/BP 4.10) X Involuntary Resettlement (OP/BP 4.12) X Safety of Dams (OP/BP 4.37) X Projects on International Waterways (OP/BP 7.50) X Projects in Disputed Areas (OP/BP 7.60) X II. Key Safeguard Policy Issues and Their Management A. Summary of Key Safeguard Issues 1. Describe any safeguard issues and impacts associated with the proposed project. Identify and describe any potential large scale, significant and/or irreversible impacts: The project does not envisage any large scale, significant or irreversible environmental impact due to the small scale interventions by the NGOs. Since the Project will be implemented by the NGOs at a community level within a limited budget, presuming the small scale community demand driven nature of the sub-projects, the Project is considered as a Category “B� which appropriate with the provision of OP 4.01. The possible sub-project activities are community-based adaptations focusing on food security, social protection and health, comprehensive disaster management, infrastructure, knowledge management etc. from the NGOs. The specific sub-project locations and their physical characteristics relevant to the safeguard analysis will be known only after approval of the proposal. Environmental screening will be performed for the subgrant selection at the appraisal stage before finalizing any sub-project activity. Any sub-project with severe environmental impact will not be funded under CCCP. The Project is expected to bring specific environmental benefits through promoting the community level climate resilience adaptation approach. However, environmentally benign projects may pose environmental damage if not properly designed from the beginning or inadequately monitored at preparation, implementation and operational stage. Social safeguards issues are anticipated only in subgrants where development of infrastructure will be one of the critical means for climate change adaptation and where tribal peoples will be affected. However, social screening will be conducted for each short-listed SGP at the appraisal stages before finalizing any climate change adaptation activity. Any sub-project with social impacts those cannot be mitigated with the current capacity of the NGO, PKSF and the community will not be funded under CCCP. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area: The selected subgrants will ensure community level intervention and maximum funding will be limited to US$ 1 million. The communities in the project area are likely to be benefited under the subgrant with the stronger climate resilience approach at local levels. The adverse environmental impacts of the project are likely to be minimal, owing to the small-scale nature of community-implemented sub-projects. No long term adverse environmental impacts are anticipated due to the possible community driven sub-project activities. Nonetheless, actual impacts will depend on the sub-project activities actually selected, i.e. the sub-project types or scheme types. Environmental safeguard risks for the CCCP are the typical ones for a rural CDD project supporting small scale basic social and economic infrastructure, and may include: (i) localized degradation or encroachment of natural habitats and associated loss of biodiversity; (ii) top soil degradation and erosion; (iii) decline in water quality; (iv) inappropriate waste disposal; (v) cutting of trees; and (vi) potential public health concerns. The Environmental Management Framework has a typical environmental screening format for identifying any potential indirect or long- term adverse impacts and taking necessary mitigation measures to ensure minimal impacts. 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. The project at this stage will not have any alternative analysis. The sub project preparation will consider alternative options considering environmental and social impact. 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. Palli Karma Shayak Foundation (PKSF) is an apex organization established by Government of Bangladesh who disburses fund to microfinance institutions (MFIs). The MFIs are the Partner Organizations (POs) of PKSF which implement development programs designed for the poor of Bangladesh. Although, PKSF has prior experience to work with World Bank funding, currently PKSF has no experienced person to deal with environmental and social safeguard issues as required by the Bank policies. In addition, since the implementing NGOs are yet to be identified, the institutional capacity for safeguard policies of the implementing body cannot be determined at this stage. PKSF has agreed to appoint a full time Program Officer (Environment) and will ensure safeguard practice during the project implementation by the selected NGOs. However, considering the project’s objective to promote climate resilience activities, the capacity building initiative will be limited to the EMF/SMF implementation. PKSF will include in its project management cell, a Program Officer (Training, Community and Social Development) who will oversight monitoring of social issues including social safeguards. The project staffs and NGOs will receive briefing on EMF/SMF during their orientation for project implementation. The subgrants to be financed under CCCP will be identified and approved during implementation phase of CCCP. Consequently, specific information on types of subgrants, site/location of the sub-projects, land requirements, local communities, geo- physical land features and nature is not available. Therefore, exact details and intensity of environmental and social impacts and their effective mitigation cannot be determined during project preparation. An Environmental Management Framework (EMF), a Social Management Framework (SMF) and an Operational Manual have been prepared to establish the mechanism to determine and assess future potential environmental and social impacts of subgrants that are to be identified and cleared based on a community demand driven process, and to set out mitigation, monitoring and institutional measures to be taken during implementation and operation of the sub-projects to eliminate adverse environmental and social impacts, offset them, or to reduce them to acceptable limit. The implementation experiences of CDD project of Bangladesh like Social Investment Program Project (SIPP), Local Governance Support Project (LGSP) and Employment Generation Program for the Poorest (EGPP) have been reviewed and the findings are used in preparing the EMF and environmental screening format for the CCCP.The EMF has the following features: (a) procedures for screening; (b) tools for assessment at a sub- project level; (c) training requirements, development of communication materials; (d) monitoring requirements; (e) and reporting procedures to be followed. The SMF provides guidelines and principles to ensure integration of social issues with the possible climate change adaptation subgrants to be identified and implemented at the community level. The SMF includes (a) procedures for screening; (b) tools for social safeguards screening, (c) tools for assessment of impacts and mitigation measures, documenting contribution of assets, and compensation for affected persons; (d) indicators for monitoring impacts on tribal populations; and (e) framework for monitoring social inclusion in identification, formation and implementation of subgrants. All shortlisted subgrants at the appraisal stage will be screened based on the requirements of the SMF prior to sanctioning. 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. The field level implementing NGO will be responsible to screen, identify, take mitigation measures and monitor the environmental and social issues in preparation, implementation and operation & maintenance (O&M) phase in consultation with the community. The NGO will screen all the sub-projects for environmental and social safeguards compliance issues and submit the screening results with the proposal. If any environmental and social issues have been identified, NGO will propose the possible mitigation measure and monitoring plan. The NGO will be responsible for conducting the Initial Environmental Examination and submit the IEE report with the proposal, if necessary. NGO will submit the quarterly monitoring report on environmental and social compliance at project preparation, implementation and operation & maintenance phase. The proposal review committee at PKSF will review the mitigation and monitoring plan submitted with the proposal. PKSF appointed Program Officer (Environment) will monitor the environmental safeguard and Program Officer (Training, Community and Social Development) will oversight monitoring of social safeguards issues in the sub- projects and publish annual report on safeguards compliance for each subgrant. These Program Officers (Environmental and Social) will maintain a database for sub-project specific environmental and social screening, and mitigation measures. The project M&E system will capture that information as well. In addition, the project’s third party evaluation (reputed local think-tank) will include a brief environmental and social audit to assess and evaluate the quality of environmental and if any, social compliance of the subgrants. PKSF has prepared the EMF and SMF in consultation with some potential NGOs. In addition, field visits were made to understand the environmental concerns of the community due to the on-going projects of PKSF. Since the subgrants under CCCP are yet to be identified, it was not possible to consult with the project beneficiaries or affected persons at this stage. However, the frameworks are prepared in such way that community consultations during the concept and appraisal stage are mandatory. The EMF and SMF have been posted in the website of PKSF along with a Bangla summary version and have been kept in the PKSF offices for further comments and inputs from non-governmental organization, civil society and general public. The EMF and SMF will be finalized taking into consideration of the comments received on draft version and will be available in PKSF and CCCP websites. The Project Implementation Partners (PIPs) have to make the hardcopy available at their head and local offices. PIP will also upload the final versions of the EMF and SMF along with the Bangla Summaries in their website, if available. B. Disclosure Requirements Date Environmental Assessment/Audit/Management Plan/Other: Was the document disclosed prior to appraisal? Yes Date of receipt by the Bank 12/21/2011 Date of "in-country" disclosure 12/31/2011 Date of submission to InfoShop 01/11/2012 For category A projects, date of distributing the Executive Summary of the EA to the Executive Directors Resettlement Action Plan/Framework/Policy Process: Was the document disclosed prior to appraisal? N/A Date of receipt by the Bank Date of "in-country" disclosure Date of submission to InfoShop Indigenous Peoples Plan/Planning Framework: Was the document disclosed prior to appraisal? Yes Date of receipt by the Bank 12/21/2011 Date of "in-country" disclosure 12/31/2011 Date of submission to InfoShop 01/11/2012 Pest Management Plan: Was the document disclosed prior to appraisal? Date of receipt by the Bank Date of "in-country" disclosure Date of submission to InfoShop * If the project triggers the Pest Management and/or Physical Cultural Resources, 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 (to be filled in when the ISDS is finalized by the project decision meeting) 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 Sector Manager (SM) Yes review and approve the EA report? Are the cost and the accountabilities for the EMP incorporated in the Yes credit/loan? OP/BP 4.10 - Indigenous Peoples Has a separate Indigenous Peoples Plan/Planning Framework (as N/A appropriate) been prepared in consultation with affected Indigenous Peoples? If yes, then did the Regional unit responsible for safeguards or Sector N/A Manager review the plan? If the whole project is designed to benefit IP, has the design been reviewed Yes and approved by the Regional Social Development Unit or Sector Manager? The World Bank Policy on Disclosure of Information Have relevant safeguard policies documents been sent to the World Bank's Yes Infoshop? Have relevant documents been disclosed in-country in a public place in a Yes 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 responsibilities Yes been 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 Yes monitoring of safeguard impacts and measures related to safeguard policies? Have satisfactory implementation arrangements been agreed with the Yes borrower and the same been adequately reflected in the project legal documents? D. Approvals Signed and submitted by: Name Date Task Team Leader: Ms Yuka Makino 01/11/2012 Environmental Specialist: Ms Nadia Sharmin 01/11/2012 Social Development Specialist Mr Md. Akhtaruzzaman 01/11/2012 Additional Environmental and/or Social Development Specialist(s): Approved by: Regional Safeguards Coordinator: Mr Sanjay Srivastava 02/09/2012 Comments: cleared. Please email from Zia dt 12/15/2011 for details. Sector Manager: Mr Herbert Acquay 02/15/2012 Comments: