Document of The World Bank FOR OFFICIAL USE ONLY Report No: 68487-BD PROJECT APPRAISAL DOCUMENT ON A PROPOSED GRANT IN THE AMOUNT US$ 12.5 MILLION TO THE PEOPLE’S REPUBLIC OF BANGLADESH FOR A COMMUNITY CLIMATE CHANGE PROJECT June 17, 2012 This document has a restricted distribution and may be used by recipients only in the performance of their official duties. Its contents may not otherwise be disclosed without World Bank authorization. CURRENCY EQUIVALENTS (Exchange Rate Effective December 2, 2011) Currency Unit = Taka Taka 77 = US$1 FISCAL YEAR July 1 – June 30 ABBREVIATIONS AND ACRONYMS ADB Asian Development Bank BCCRF Bangladesh Climate Change Resilience Fund BCCSAP Bangladesh Climate Change Strategy and Action Plan CAS Country Assistance Strategy CBO Community-Based Organization CCCF Community Climate Change Fund CCCP Community Climate Change Project CHT Chittagong Hill Tracts CRP Concept Review Phase CSO Civil Society Organization DFID Department for International Development DP Development Partner EMF Environmental Management Framework GOB Government of Bangladesh GRM Grievance Redress Mechanism IFAD International Fund for Agricultural Development IPP Indigenous Peoples Plan MOEF Ministry of Environment and Forests NAPA National Adaptation Program of Action NGO Non-Government Organization OM Operational Manual OP Operational Policy PCN Project Concept Note PC Project Coordinator PDO Project Development Objectives PIP Project Implementing Partners PO Program Officer PKSF Palli Karma-Sahayak Foundation PMU Project Management Unit PRP Proposal Review Phase SGP Sub-grant Proposal SMF Social Management Framework VCA Vulnerability and Capacity Analysis Regional Vice President: Isabel Guerrero Country Director: Ellen Goldstein Sector Director: John Henry Stein Sector Manager: Herbert Acquay Task Team Leader: Yuka Makino BANGLADESH Community Climate Change Project TABLE OF CONTENTS Page I. STRATEGIC CONTEXT .................................................................................................1 A. Country Context…………………………………………………………………………...1 B. Sectoral and Institutional Context ....................................................................................... 1 C. Rationale for Bank Involvement ......................................................................................... 3 D. Higher Level Objectives to which the Project Contributes ................................................ 3 II. PROJECT DEVELOPMENT OBJECTIVES ................................................................3 A. Project Development Objectives (PDO) ............................................................................. 3 B. PDO Level Results Indicators ............................................................................................. 4 III. PROJECT DESCRIPTION ..............................................................................................4 A. Project Components ............................................................................................................ 4 B. Project Financing ................................................................................................................ 5 C. Lending Instrument ............................................................................................................. 5 D. Project Cost and Financing ................................................................................................. 5 E. Lessons Learned and Reflected in the Project Design ........................................................ 6 IV. IMPLEMENTATION .......................................................................................................6 A. Results Monitoring and Evaluation .................................................................................... 9 V. KEY RISKS AND MITIGATION MEASURES ..........................................................10 VI. APPRAISAL SUMMARY ..............................................................................................11 A. Technical, Economic and Financial Analyses…………………..……………………….11 B. Financial Management …….……………..……………… ……..…………………….12 C. Procurement ...................................................................................................................... 12 D. Social ................................................................................................................................. 13 E. Environment ...................................................................................................................... 14 Annex 1 Results Framework and Monitoring…………………………………………………………….16 Annex 2 Detailed Project Description…………………………………………………………………….20 Annex 3 Institutional and Implementation Arrangements………………………………………………..26 Annex 4 Operational Risk Assessment Framework (ORAF)…………………………………………….58 Annex 5 Implementation Support Plan…………………………………………………………………...61 Bangladesh Community Climate Change Project PROJECT APPRAISAL DOCUMENT South Asia SASDI Basic Information Date: Sector(s): Other social services (34%); Flood protection (33%); General agriculture, fishing and forestry sector (33%) Country Director: Ellen Goldstein Sector Director: Theme(s): Climate change (70%); Natural disaster John Henry Stein management (15%); Other social protection and risk management (15%) Sector Manager: Herbert Acquay Team Leader: EA Category: B Yuka Makino Project ID: P125447 . Borrower: Government of Bangladesh Responsible Agency: Palli Karma-Sahayak Foundation (PKSF) Contact Person: Dr. Quazi Mesbahuddin Ahmed Title: Managing Director Telephone No: (880-2) 9140246 Email: qmahmed@pksf-bd.org Fax: (880-2)9134431 . Project Implementation Start August 1, 2012 End December 31, 2016 Period: Date: Date: Expected Effectiveness Date: August 1, 2012 Expected Closing Date: December 31, 2016 . Project Financing Data(US$M) [ ] Loan [X] Grant [ ] Other [ ] Credit [ ] Guarantee Total Project Cost : 12.5 . Financing Source Amount(US$M) Bangladesh Climate Change Resilience 12.5 Fund (Recipient Executed Trust Fund) Total . Expected Disbursements (in USD Million) Fiscal Year 2013 2014 2015 2016 2017 Annual 3.0 3.0 0.4 3.1 3.0 Cumulative 9.1 12.1 12.5 3.1 6.1 . 1. Project Development Objective(s): To enhance the capacity of selected communities to increase their resilience to the impacts of climate change. This is expected to be achieved through the establishment of an effective grant financing mechanism within PKSF to channel funds to non-governmental organizations. Components 1. Community Climate Change Fund (US$10.40 million) 2. Knowledge Management, M&E and Capacity (US$ 0.44 million) building 3. Project Management (US$ 1.66 million) . Compliance Policy Does the project depart from the CAS in content or in other significant respects? Yes [ ] No [x ] . Does the project require any waivers of Bank policies? Yes [ ] No [ x ] Have these been approved by Bank management? Yes [ ] No [ ] Is approval for any policy waiver sought from the Board? Yes [ ] No [ x ] Does the project meet the Regional criteria for readiness for implementation? Yes [ x] No [ ] . Safeguard Policies Triggered by the Project 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 . Legal Covenants Name Recurrent Due Date Frequency Description of Covenant . Team Composition Bank Staff Name Title Specialization Unit UPI Yuka Makino Task Team Leader Sr. Natural Resources SASDI 207674 Management Specialist Khawaja M. Minnatullah Consultant Sr. Environment and Water SASDI 23266 Specialist Nadia Sharmin Consultant Environment Specialist SASDI 359622 Md. Akhtaruzzaman Consultant Social Development SASDT 381377 Specialist Teen Kari Barua Consultant Social Development SASDT 107052 Specialist Marghoob Bin Hussein Sr. Procurement Procurement SARPS 271557 Specialist Muhammed Riadul Islam Procurement Specialist Procurement SARPS 356433 Burhanuddin Ahmed Sr. Financial Financial Management SARFM 247625 Management Specialist Jose Ramon R. Pascual Counsel Legal LEGES 304441 Junxue Chu Senior Finance Officer Disbursement CTRLN 153387 Nicholay Christyakov Senior Finance Officer Disbursement CTRLN 86221 Arun Banerjee Consultant SASDI 4891 Anna O'Donnell Social Development SASDS 259278 Specialist Mohammad Baharul Program Assistant SASDO 273447 Alam Marie Florence Elvie Program Assistant . Locations Country First Location Planned Actual Comments Administrative Division/District Bangladesh Chuadanga, The planned locations Jessore, Naogaon, are identified based Rajshahi, Satkhira, upon climate risk Natore, Khulna, (drought, flood and Bagerhat, saline water intrusion) Patuakhali, and poverty levels. The Barguna, Barisal, actual locations will be Cox’s Bazar, determined by the Jamalpur, successful NGO Mymensingh, proposals. Kurigram, Nilphamari . I. STRATEGIC CONTEXT A. Country Context 1. During the past decade, Bangladesh’s GDP grew by close to 6 percent per annum (Bangladesh Country Assistance Strategy [CAS] 2011-2014). Yet Bangladesh remains a low- income country, with a third of its population living in poverty. With nearly 151 million inhabitants on a landmass of 147,570 km2, it is the most densely populated climate-vulnerable country in the world. Two-thirds of the country’s land area is less than 5 meters above sea level and is susceptible to river and rainwater flooding, particularly during the monsoons. Once every three to five years, these areas are inundated by floods that cause substantial damage to infrastructure, housing, agriculture and livelihoods. Low-lying coastal areas are also at risk from tidal floods and severe cyclones. Once every three years, on average, a severe cyclone makes landfall on the Bangladesh coastline, creating storm surges that are sometimes in excess of 10 meters. Crops and livelihoods of the rural poor in the low-lying coastal areas are also devastated by saline water intrusion into aquifers and groundwater and through land submergence. In addition, seasonal droughts occasionally hit the northwestern region. B. Sectoral and Institutional Context 2. The frequency and intensity of these extreme climatic events are expected to increase because of climate change, with devastating economic, social and ecological consequences. A 2010 World Bank report1 predicted that climate change will decrease agricultural GDP in Bangladesh by 3.1 percent each year. Around 80 percent of total losses fall directly on household consumption and therefore have severe household welfare implications. The southern coastal and northwestern regions are expected to experience the largest income decline. Other impacts of more frequent and intense climatic events include: (1) loss of key economic infrastructure and livelihood resources; (2) saline water intrusion into coastal aquifers and areas; and (3) loss of biodiversity. 3. Bangladesh has put in place an extensive set of risk mitigation measures to enhance its preparedness for disasters. Households have also needed to adapt to reduce exposure to these risks and to maintain their livelihoods. While these measures have significantly reduced damage and losses from extreme events over time, especially in terms of deaths and injuries, additional measures are needed to further reduce the risks from climate-related hazards. A number of these measures are already in place in Bangladesh, including both hard infrastructure and soft policy measures combined with communal practices. Hard infrastructure include coastal embankments, foreshore afforestation, cyclone shelters, early warning systems; soft measures include changes in design of roads, migration of people from high-risk coastal areas, and changes in cropping patterns. These measures have made the country more resilient in facing climate hazards, and fatalities and income losses have been reduced. 4. The risks from climate variability and change are geographically concentrated in six specific regions of the country, which also have higher concentrations of the poor—the subsistence farmers, the rural landless, fishing communities, and urban poor. The areas are 1 Bangladesh: Economics of Adaptation to Climate Change (2010) 1 largely defined by their physiology and ecology and have varying climate change risks: (a) the South, Southwest, and Southeast coastal region is at risk from increasingly frequent and severe tropical cyclones, sea level rise causing drainage congestion, and saline intrusion in surface and ground water and soil; (b) the Northwest Barind Tract is prone to drought; (c) the Northeast haor or freshwater wetland area is alternately impacted by delayed rainfall or early flooding, and sedimentation from erosion of the surrounding hill areas; (d) the Central char and floodplains are prone to flooding, flash floods, and river bank erosion; (e) the Hill Tracts are prone to landslides; and (f) the urban areas are impacted by drainage congestion. 5. The Government of Bangladesh recognizes that climate change is both an environmental and developmental issue, and has prepared a number of strategy documents to guide the country’s response. The National Adaptation Program of Action (NAPA), prepared in 2005 and updated by the Ministry of Environment and Forests (MOEF) in 2009, identified key climate change issues and recommended 45 specific regional adaptation strategies targeting the coastal region, including the islands; as well as the Northeast, Northwest, Central, Char-land/floodplain, and Southwest regions. The 2009 Bangladesh Climate Change Strategy and Action Plan (BCCSAP) also reinforces the country’s commitment to take all measures to protect people from the impacts of climate change, and makes adaptation a priority. This strategy and action plan has the following six pillars: (a) address the impacts of climate change on food security, social protection and health; (b) further strengthen the country’s comprehensive disaster management capacity; (c) climate proof existing infrastructure; (d) improve research and knowledge management to predict the likely scale, timing, and impact of climate change on different sectors; (e) incorporate mitigation and low carbon opportunities for future growth; and (f) focus on capacity building and institutional capacity. 6. To support implementation of the BCCSAP, the Government, in collaboration with development partners, established a multi-donor trust fund, the Bangladesh Climate Change Resilience Fund (BCCRF), in 2010 under the purview of the MOEF. The United Kingdom, Sweden, European Union, Switzerland, and Denmark have committed a total of US$125 million in grant funding to the BCCRF. The fund is being temporarily administered by the World Bank. Development partners have signed an agreement with the Bank ensuring its sound fiduciary management. 7. The BCCRF is designed as a one-stop mechanism for large-scale climate change financing in Bangladesh. It has two windows: an on-budget window for funding public sector projects, and an off-budget window for funding projects by non-governmental organizations (NGOs). The objectives and guiding principles for the NGO window are outlined in the BCCRF implementation manual agreed upon by MOEF and the contributing donors. In May 2011, the Governing Council of BCCRF designated the Palli Karma-Sahayak Foundation (PKSF)2 as the implementing agency for the off-budget funding window. Under this window, PKSF will 2 PKSF was established by the Government of Bangladesh in 1990 as a not-for-profit financial institution to alleviate poverty through sustainable employment generation. It has an extensive community development experience and a nationwide network of partner organizations (POs) in every district of the country. To date, PKSF has disbursed funds totaling BDT 456 billion for microfinance projects that have benefited more than 8.6 million borrowers. It has implemented projects supported by the World Bank, ADB, IFAD, DFID and other development partners. PKSF also provides technical assistance programs in the agriculture sector. 2 channel grant funds to NGO sub-projects under the proposed Community Climate Change Project (CCCP). PKSF’s previous experience with Bank-funded projects includes the First and Second Poverty Alleviation and Employment Promotion projects (1996-2006), totaling US$316 million; and the Financial Services for the Poorest (FSP) project (2002-2004), supported by a Learning and Innovation Loan (LIL) of US$5 million. PKSF is currently supporting implementation of the US$15 million Emergency 2007 Flood Restoration and Recovery Assistance Program under the Social Investment Program Project (SIPP). C. Rationale for Bank Involvement 8. The project is fully consistent with the CAS and will help achieve one of its strategic objectives—i.e., Reduce Environmental Degradation and Vulnerability to Climate Change and Natural Disasters. The project is also an essential part of the Government’s strategy for adapting to climate change. It has received strong endorsement from a wide range of stakeholders, who have actively participated in refining the project concept. It is also supported by the community of local NGOs committed to developing local-level capacity to cope with climate change. D. Higher-Level Objectives to which the Project Contributes 9. The proposed operation would support several of the strategic objectives of the Climate Change Strategy and Action Plan (BCCSAP). It will specifically support the pillar of the action plan aimed at: (a) strengthening the country’s disaster management capacity; (b) climate proofing some existing infrastructure; and (c) improving research, knowledge management and institutional capacity. Recognizing the importance of climate change to the development of Bangladesh, the Bank Group has proposed a lending program of US$1.2 billion for the 2011- 2014 CAS objective of “reduc[ing] environmental degradation and vulnerability to climate change and natural disasters.� This project will contribute to achieving two CAS outcomes— strengthened water resources management and coastal protection; and enhanced disaster preparedness. II. PROJECT DEVELOPMENT OBJECTIVES A. Project Development Objectives (PDO) 10. The Project Development Objective is to enhance the capacity of selected communities to increase their resilience to the impacts of climate change. 11. An intermediate indicator of success will be the establishment of an effective grant financing mechanism within PKSF to channel funds to NGOs to fund community-based climate change adaptation activities. B. Project Areas and Beneficiaries 12. The target upazilas, or sub-districts, were identified based on their degree of exposure to climate risk and level of poverty. Initially the project will focus on three climate risks prevalent in Bangladesh: saline water intrusion, drought, and flood. A list of upazilas is provided in Annex 3 2. The target climate risk areas may be expanded during the project period upon successful implementation of project activities. 13. The primary beneficiaries of the project will be communities in saline-affected, flood- affected and rainfall-scarce zones of the country. Secondary benefits will accrue to the PKSF and participating NGOs, which will develop enhanced capacity to plan and implement effective community-driven climate change adaptation projects. C. PDO-Level Results Indicators Key outcomes expected at the end of project implementation are as follows: i. Community mechanisms established and functioning in selected communities to respond effectively to specific climate risk ii. Communities to have applied sustainable adaptation practices to address specific climate change risk iii. Sub-grants implemented in the selected communities are assessed to have achieved the targeted objectives III. PROJECT DESCRIPTION A. Project Components Component 1. Community Climate Change Fund (US$10.40 million) 14. 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. 15. 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$1 million, and all would be completed three months before the completion date of the CCCP. The proposals would also be reviewed for social and environmental safeguards, including gender and social inclusion, as per Bank policy. The details of the process by which sub-grants would be awarded are given in Annex 3. 4 Component 2. Knowledge Management, Monitoring and Evaluation, and Capacity building (US$ 0.44 million) 16. 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. 17. 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) 18. This component would finance technical assistance to: (a) establish a PMU within PKSF to manage the Community Climate Change Project 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). B. Project Financing 1. Lending Instrument 19. The lending instrument for the proposed project would be a Trust Fund Grant to be provided as a US$12.5 million grant from the multi-donor BCCRF to the PKSF. The PKSF would in turn provide sub-grants to finance sub-projects that would be implemented by NGOs. 2. Project Cost and Financing The detailed breakdown of the project costs are given in Annex 2 and summarized below: 5 Project Components Project cost BCCRF Financing % Financing 1. Community Climate Change Fund US$ 10.40 m US$ 10.40 m 100% 2. Knowledge Management, M&E and Capacity US$ 0.44 m US$ 0.44 m 100% Building US$ 1.66 m US$ 1.66 m 100% 3. Project Management Total Project Cost US$ 12.5 m US$ 12.5 m 100% C. Lessons Learned and Reflected in the Project Design 20. The CCCP design is based on lessons learned from previous projects on disaster management and climate change in Bangladesh; on previous projects implemented through grants to NGOs in Bangladesh; and on international experience with funding mechanisms for climate change adaptation activities. The following key lessons have been incorporated into the project design:  Transparency is essential for ensuring an efficient and effective grant process. CCCP has developed simple screening criteria for determining eligible NGOs and sub-project proposals, which will be clearly outlined on the project website in Bangla and English. The screening and approval process will be conducted in three steps: (i) institutional and concept review; (ii) technical appraisal of the sub-project proposal; and (iii) PKSF Governing Body approval. A project process and impact monitoring system needs to be incorporated into the design to ensure that the objectives of the project are being met. CCCP will adopt an MIS system that will be used by both PKSF and the implementing NGOs to conduct day-to-day monitoring of overall and sub-project activities. Annual third party impact monitoring will also be conducted to determine whether the objectives are being met.  Adaptation interventions need to be evaluated based on their approach to the specific climate risk in each zone.  Long-term vision and sustainability are essential for adaptation projects. CCCP focuses heavily on building the capacity of PKSF to serve as a permanent institutional mechanism for channeling climate adaptation funds. IV. IMPLEMENTATION A. Institutional Arrangements 21. Project implementation will involve the following Government institutions:  Ministry of Environment and Forests (MOEF) will be the coordinating ministry on behalf of the Government;  Bangladesh Climate Change Resilience Fund (BCCRF) will provide the funds for this project as well as exercise some broad fiduciary controls through its Governing Council and Management Committee (further details in Annex 3); 6  PKSF will receive the funds from BCCRF and be responsible for overall implementation of the project. BCCRF 22. The Bangladesh Climate Change Resilience Fund (BCCRF) is a partnership among the Government of Bangladesh, the World Bank, and other development partners to address the impacts of climate change. Its objective is to support implementation of Bangladesh Climate Change Strategy and Action Plan (BCCSAP). The Government is leading the management and implementation of BCCRF. On behalf of the contributing development partners, and in consultation with the Government, the World Bank is ensuring that the Fund meets due diligence requirements in terms of financial management and implementation. Details of BCCRF’s governing structure and operations are in Annex 3. PKSF 23. PKSF was established in 1990 as an umbrella organization with the mandate for poverty alleviation through employment generation. PKSF disburses funds to microfinance institutions (MFIs) who are its Partner Organizations to implement programs designed for the poor of Bangladesh. In its first decade, PKSF focused on strengthening program implementation and institutional development of its Partner Organizations. In its second decade, PKSF shifted gears to accommodate the economic and social changes taking place in Bangladesh. As PKSF begins its third decade, it intends to address multi-dimensional aspects of development, including generating employment and providing comprehensive development support with programs such as health, education, and skill development. The proposed project represents this new direction. Details of the PKSF organization are in Annex 3. Project Management Unit in PKSF 24. PKSF will establish a PMU with suitable office facilities to manage the CCCP. A Project Coordinator (PC) will head the PMU and be in charge of overall implementation. He/she will directly report to a senior official of PKSF and be the first contact person at PKSF for the BCCRF Secretariat, the World Bank, and other development partners involved in the CCCP. The PC will report to the BCCRF through the designated senior PKSF official. 25. The PMU will engage several Program Officers (POs) to liaise with the implementing NGOs, known as project implementing partners (PIPs). The PIPs will receive sub-grants from the CCCP throughout the project implementation process. The PMU will engage minimum of 6 POs. The number of POs will depend on the number of PIPs and the number PIPs to be allocated to each PO will depend on the size, geographical location and nature of the projects. The POs will be the first contact points for the PIPs, and will report to the PC. 7 Project Management Setup PKSF Governing Body BCCRF The World Bank MD/Sen official PKSF Technical Project Secretary Experts Coordinator Senior Accounts Accounts & Admin/ Deputy M&E MIS PO s &Finance Officer Finance Officer PC/Procurement Specialist Specialist Project Implementing Partners (PIP) 26. The Program Officers will have backgrounds in climate change adaptation, environment, a community/social development, agriculture, water resources management, disaster management, knowledge management, and other relevant areas, and will ensure that environmental and social safeguard issues are properly addressed in all CCCP activities. In addition, an M&E officer in the central M&E unit of PKSF will provide technical guidance to POs on monitoring the sub-projects, and will report to both the head of M&E and the Project Coordinator in the PMU. A Senior Accounts and Finance Officer, and Administrative/Procurement and Logistics Officer dedicated to CCCP will work under the technical supervision of PKSF’s Finance, Accounts and Audit Section and under the administrative guidance of the PMU. 27. The PMU will also prepare a roster of technical reviewers and use their services as and when required to evaluate and appraise sub-project proposals. These technical experts will represent different thematic areas listed in the BCCSAP and different technical disciplines relevant to climate change adaptation (e.g., water, health, irrigation, agriculture, aquaculture, livestock, infrastructure, disaster management, gender, community development, ecosystem management, organizational development, project management, financial management, coastal livelihoods, local governance and advocacy, etc.). Experts must have proven record of at least five years in the area of development and climate change and a relevant management/ academic/research background. 28. For each sub-project proposal, the PC will designate an evaluation team led by one of the POs, and one or more of the technical reviewers, depending on the nature, scope and size of the proposal. The PO heading each team will be responsible for preparing the appraisal report and recommendations on behalf of the team. The proposals will be evaluated by sector and region to expedite the review process. 8 B. The World Bank, PKSF Governing Body and the BCCRF Secretariat 29. The PKSF will keep the World Bank informed of all relevant matters and send the evaluations and recommendations for sub-projects to the World Bank to ensure their compliance with Bank fiduciary requirements. Once cleared by the World Bank, sub-projects will be submitted to the PKSF Governing Body for final approval. PKSF will also report to BCCRF Management Committee on the progress of CCCP on a semi-annual basis. C. Grant Awarding Procedures for the Community Climate Change Fund 30. Guiding Principles. CCCP will provide sub-grants to NGOs to implement sub-projects focused on community-based climate change adaptation activities. The guiding principle in the design of the grant award system is “simplicity with transparency,� so award decisions will be made in the shortest time possible, and activities will be carried out efficiently and meet all safeguard requirements without compromising the quality of outputs. 31. The selection of NGOs’ sub-projects and the award of sub-grants will be done in two phases: a Concept Review Phase (CRP), in which NGOs will establish their eligibility to receive sub-grants; and a Proposal Review Phase (PRP), in which sub-project proposals will be evaluated by a team of experts, using agreed-upon climate change-related criteria, after which sub-grants will be awarded. There will be one call for proposals at the project launch targeting the priority climate risk regions. Details of PKSF’s sub-grant funding mechanism are provided in Annex 3. 32. The aim of the Concept Review Phase is to determine whether the NGO has the institutional and financial capacity to proceed to the next phase of preparing a full sub-project proposal, based its legal registration and financial and institutional reports. The NGO must also have an established presence and ongoing activities in one of the target upazilas to ensure that the proposed sub-project builds on its experience in the area. The NGO will be required to submit a Concept Note with a brief description of the proposed sub-project, and demonstrate that the project qualifies as an “adaptation� project addressing at least one of the pillars of the BCCAP. The evaluation team will be composed of only evaluators who have no conflict of interest with the NGO being evaluated. There will be automatic disqualification of both evaluators and NGOs if there are conflicts of interest which are not declared. 33. The Proposal Review Phase applies only to sub-project proposals that have passed the Concept Review Phase. The proposals will be submitted in a prescribed format and evaluated by an Evaluation Team headed by a Program Officer, with input from technical experts as needed. There will be automatic disqualification of both evaluators and NGOs if there are conflicts of interest. D. Results Monitoring and Evaluation 34. The project will be monitored at three levels – (1) achievement of outcome of the project, (2) the performace of PKSF in the establishment and implementation of the sub-grant financing mechanism, and (3) the performance of NGOs in the implementation of the sub-grants. An annual Third Party outcome monitoring; and Mid-term and completion Impact evaluation will be 9 conducted to determine the progress towards the achievement of the project development objectives. PKSF will be responsible for setting-up a functioning Project Management Unit (PMU), the sub-grant mechanism, and ensuring effective implementation of the fiduciary aspects throughout the project including environmental management, social assessment and management, financial management, and procurement management. A third party monitoring will be conducted as frequently as necessary, to assess the effectiveness of PKSF as the implementing agency and monitor the sub-projects implemented by NGOs for adressing the climate risk for each of the selected regions. 35. Each sub-project will be subject to monitoring both by the implementing NGO and by PKSF. However, the frequency and subject of monitoring will differ. A detailed M&E manual consistent with PKSF’s overall results-based monitoring system has been prepared and will guide the monitoring practices. 36. Monitoring under CCCP will have three functions. First, it will ensure that implementing NGOs deliver on agreed outputs, which will indicate that sub-grant resources are being used efficiently for the proposed activities. Second, monitoring will establish proper documentation of the implementation process and achievements at different levels (outputs, outcomes and impacts). Third, monitoring will help capture learning about climate change adaptation in different contexts, thereby add to the knowledge base for future actions. In short, the role of accountability is a significant monitoring issue at the level of outputs, whereas learning becomes a core issue at the level of outcomes and impacts. V. KEY RISKS AND MITIGATION MEASURES The potential project risks and proposed mitigation measures are summarized below. Risks Risk Mitigation Measures Risk Rating Capacity: PKSF is a microfinance PKSF will establish a PMU for project implementation. Substantial organization, and may lack the The project will establish objective assessment criteria to specific technical and management screen and select NGOs. An Evaluation Team consisting of experience to execute and supervise appropriate technical experts will screen and evaluate each the program. NGO proposal prior to their being approved for funding. At the NGO level, implementation of the sub-projects will be done by suitable technical staff, with supervision by technical experts from the PMU. Governance: External influences PKSF has a governance structure in place with a Governing Moderate could challenge PKSF’s ability to Body that is well established. Proposals will be reviewed maintain oversight and transparency. by technical experts hired by PKSF. The PMU will be provided with sufficient resources to hire the necessary staff to maintain oversight with transparency. World Bank will provide support on fiduciary aspects. Design: Possible difficulties in A PMU with multi-disciplinary expertise will be established Substantial identifying useful adaptation sub- in PKSF to specifically oversee the implementation of the projects/activities, and the limited CCCP project. In addition, an extensive communication timeframe for achieving impacts. package will be developed along with workshops to raise the awareness of NGOs preparing adaptation proposals. PMU will also provide assistance to NGOs at both proposal 10 Risks Risk Mitigation Measures Risk Rating preparation phases as well as during implementation, as necessary. Finally, a comprehensive monitoring and feedback mechanism will ensure continual learning from experience. Social and environmental: PKSF has prepared an Environment Management Substantial Specific sub-projects have not been Framework (EMF) and Social Management Framework identified. In addition, there is weak (SMF) that involve mandatory community consultations capacity to ensure environmental during the concept and appraisal stages of sub-projects. and social safeguards and implement PMU will have full-time POs with backgrounds in environmental and social manage- environmental and social safeguards, including gender and ment plans. social inclusion. PMU will develop its own monitoring plan to oversee environmentally and/or socially sensitive sub- projects. The specialist POs will be responsible for ensuring safeguard compliance at concept, proposal, implementation and monitoring stages. Program and donors: The project Substantial is being funded through a multi- Close partnership and communication during project donor trust fund, which will require preparation and implementation with donor partners to continuous investments over the solidify commitment for the longer term. Documenting long term to have any significant lessons learned for continuous improvement and the impact. Furthermore, the creation dissemination and communication of results to demonstrate and strengthening of institutions is a impacts on the ground. Government has already committed long-term process. Therefore, the some of its own Climate Change Fund to PKSF to continue trust fund will require long-term the program. donor support. Delivery, monitoring, and Close partnership with donors and PKSF to document Substantial sustainability: This is the first lessons learned. A strong monitoring and evaluation plan to climate change adaptation program ensure that achievements are highlighted and disseminated to be implemented by PKSF, and and communicated effectively. constitutes establishment of a new institutional mechanism for grant financing and M&E. The overall risk rating is Substantial because of: (i) Substantial uncertainty about the location of the sub-projects, and the potential safeguards risks that this poses; (ii) the potentially Overall Risk Rating: large number of sub-projects to be monitored for compliance and effectiveness; (iii) the general challenges of implementing a climate change adaptation project with imperfect information. VI. APPRAISAL SUMMARY A. Technical, Economic and Financial Analyses 37. The types of sub-projects to be financed will vary according to the three climates risk areas where activities are proposed: salinity-affected coastal areas, flood-affected areas and river basins, and drought-affected or rainfall-scarce areas. An indicative list of the kinds of activities likely to be financed includes: 11  Large reserve ponds (dighis) in saline areas for sweet water  Solar-powered piped drinking water supply options for inaccessible remote villages  Access roads within the village between communities which get seasonally inundated (in flood and coastal areas)  Adaptive livelihood options, including alternative agricultural, fisheries, crab fattening, goose rearing, etc.  Saline, flood and drought-tolerant rice cultivation  Establishment of community-level climate information centers at union parishads  Various climate and disaster awareness and capacity building activities and research. 38. Since the details of the sub-projects are not yet known, it is not possible to carry out any economic or financial analysis. However, each sub-project proposal will be appraised for technical suitability and subject to certain minimum financial and economic tests, as well as adherence to the World Bank environmental and social guidelines. B. Financial Management 39. A financial management assessment of PKSF was carried out in accordance with the Financial Management Investment Operation directive issued by the Financial Management Sector Board on March 1, 2010. The objective of the assessment was to determine whether the implementing agency, PKSF, has acceptable financial management arrangements, as evidenced by: (i) use of funds in an efficient and economical way, for the purposes intended; (ii) the preparation of accurate, reliable and timely periodic financial reports; and (iii) the safeguarding of PKSF assets. 40. The assessment concluded that the financial management risk rating of the project is "Substantial." To address the identified processes weaknesses in fund flow reporting and mitigate the risks, an overall financial management arrangement has been agreed with the implementing agency. The assessment concluded that with the implementation of these actions, the proposed financial management arrangements will satisfy the Bank's minimum requirements under OP/BP 10.02. 41. There are no audit reports and interim financial reports that are overdue to the World Bank. "Guidelines on Preventing and Combating Fraud and Corruption in Projects financed by IBRD Loans and IDA Credits and Grants," dated October 15, 2006 shall apply to the project. Taking into account the risk mitigation measures proposed, the overall financial management residual risk for this project would be "Moderate." Detailed information on the project’s financial management arrangements is in Annex 3. C. Procurement 42. An assessment of PKSF has been carried out to evaluate its procurement systems and assess procurement risks. PKSF has limited experience with procurement of goods and services under World Bank-funded projects and may need technical support during implementation. The procurement risk is assessed as “Substantial.� All procurement activities will be centralized at 12 the PMU level and overseen by the Deputiy Project Coordinator specialized in procurement. With the procurement arrangements and monitoring through procurement performance improvement plan (PPIP) specified in detail in the implementation arrangements, project procurement is expected to be effective and transparent, resulting in its smooth implementation, and the residual risk related to procurement is assessed as “Moderate.�Procurement processes and implementation of contracts will be reviewed every six months by the Bank, and adjustments or corrections, including to the review threshold and scope, will be made as appropriate. D. Social 43. PKSF will select and fund innovative climate change adaptation activities by NGOs in three climate-vulnerable zones. All sub-projects, irrespective of their location and the nature of the proposed interventions, are required to integrate issues relating to social inclusion, with a particular emphasis on gender mainstreaming. Some sub-projects may include physical works to be implemented on private or public land, which may involve social safeguards. Although Chittagong Hill Tracts, which are home to the largest proportion of the country s tribal peoples (TPs), are not included in the current CCCP, some sub-project areas could still be inhabited by TPs. 44. Applicability of social safeguards policies will depend on the specific activities and communities. Under this project, any activity involving resettlement will not be eligible for funding, and any purchase of private land will be avoided wherever possible. Where public land is not available, private land may be taken through voluntary contribution or voluntary contribution with compensation to the beneficiary community. Sub-projects with adverse social and cultural impacts on TPs, which cannot be mitigated by PKSF or the implementing NGO at their current level of capacity, will not be funded. 45. With the restriction that adaptation activities cannot be implemented on lands obtained through involuntary acquisition and involving physical displacement of peoples, the OP 4.12 on Involuntary Resettlement has not been triggered. Social safeguard compliance requirements are thus likely to relate to Bank policy on Indigenous Peoples (OP 4.10) for sub-project areas inhabited by TPs. Although safeguard compliance issues will not be known until sub-project proposals are received and reviewed, PKSF has prepared a Social Management Framework (SMF) to prepare and implement Social Management Plans that address any social issues that may arise during sub-project appraisals. Even though OP 4.12 is not triggered, the SMF also includes, in addition to a tribal peoples planning framework, a set of land use guidelines consistent with OP 4.12, in the event that land-based activities are a critical part of the chosen adaptation measure. In addition to social safeguards, the SMF also provides guidance to ensure that sub-projects take into account the gender implications of vulnerability and adaptability, which are considered important to cope with and adapt to climate change impacts. The draft SMF was disclosed locally on 31st December 2011 and in the Bank Infoshop on 10 January 2012, with a request for comments for finalization. 46. The SMF includes principles, policies and guidelines to identify and mitigate any safeguard impacts that might be caused by sub-project activities. Among other provisions, it contains (a) guidelines on community consultations, including separate consultations with women and tribal peoples; (b) a list of restrictions on adaptation measures with negative social 13 attributes related to involuntary resettlement and indigenous peoples; (c) guidelines on obtaining lands for physical interventions where unavoidable; (d) guidelines for preparing Tribal Peoples Plans (TPPs) where sub-projects cause adverse impacts on TPs; and (e) a guidance note for integration of social and gender issues into sub-project selection, design and implementation. The SMF provides institutional arrangements for implementation and monitoring, and includes a grievance redress mechanism (GRM) to address complaints and grievances at the sub-project and PKSF levels. 47. Given that climate change adaptation is a new area of practice for PKSF, the agency will establish a PMU staffed with specialists and short-term experts. In addition to local and overseas training for capacity development, the PMU staff will network with or seek assistance from the World Bank and other organizations on climate change adaptation management and social safeguards compliance. A dedicated Program Officer for Training and Community/Social Development will be employed at the PMU to oversee SMF implementation. 48. Monitoring of SMF implementation will be done by the M&E unit within PKSF, and an M&E officer dedicated to CCCP will be engaged at the PMU to oversee all activities, including those related to safeguards compliance. Monitoring will be participatory at the local level, involving the communities and the PO for each selected zone. The POs will undertake quarterly field visits to validate monitoring data provided by the NGOs. The POs will work under the technical guidance of the M&E officer. 49. The sub-projects will undergo a mid-term review and an end-term evaluation, including of social safeguard compliance. After the mid-term review, corrective measures in implementation and monitoring will be undertaken as necessary. The overall project will also be evaluated externally at mid-term and completion. E. Environment 50. Environmental issues that could arise are likely to be minor. The project is identified as Category ‘B,’ since the specific environmental impacts of the possible subprojects cannot be precisely identified before sites and sub-projects are selected. The CCCP will finance community-based climate change adaptation focusing on food security, social protection and health, comprehensive disaster management, infrastructure, and knowledge management. The interventions are expected to improve community-level environmental planning, practices and management. To avoid adverse environmental impacts and enhance environmental outcomes of the individual sub-projects, OP/BP 4.01 (Environmental Assessment) been triggered for this project. Any sub-project with severe environmental impact will not be funded under the CCCP. 51. The sub-projects to be financed under the CCCP will be identified during the implementation phase; a framework approach has been adopted for this project. The implementing agency, PKSF, has prepared an Environmental Management Framework which provides screening tools to identify, during the appraisal stage, potential environmental risks in sub-projects; procedures to conduct an Initial Environment Examination (IEE) if potential negative environmental impacts are identified; procedures to mitigate any potentially adverse environmental impacts; and a monitoring mechanism. The draft EMF was disclosed both in country and in the World Bank Infoshop before appraisal. 14 52. PKSF will be responsible for managing CCCP and will invite sub-project proposals from eligible NGOs; the proposals must comply with procedures outlined in the EMF. Currently PKSF has no experienced person to deal with environmental safeguard issues, as required by Bank policies. PKSF will hire a full-time environmental specialist/focal person, as a program officer for the PMU. S/he will review the screened proposals, suggest any required mitigation measures, and ensure that activities with significant negative impacts are not selected and implemented. 53. As part of the monitoring of sub-project implementation and operation, the NGO nominated environmental focal person will monitor compliance with environmental requirements and submit quarterly monitoring reports to PKSF on the environmental compliance of sub-grants. PKSF’s environmental officer in the PMU will monitor all environmental safeguard issues in the selected sub-projects and publish an annual report on environmental compliance of sub-projects. PKSF will develop its own monitoring plan to oversee environmentally critical sub-projects. A database will be maintained for sub-project-specific environmental screening and mitigation measures. The project M&E system will capture that information as well. In addition, the project’s third party evaluation will include a brief environmental audit to assess and evaluate the quality of environmental compliance of the sub- projects. The Bank would also supervise environmental compliance as part of regular implementation support missions. Safeguard Policies Safeguard Policies Triggered by the Project Yes No Environmental Assessment (OP/BP 4.01) [X] [] Natural Habitats (OP/BP 4.04) [] [X] Pest Management (OP 4.09) [] [X] Physical Cultural Resources (OP/BP 4.11) [] [X] Involuntary Resettlement (OP/BP 4.12) [] [ X] Indigenous Peoples (OP/BP 4.10) [X] [] Forests (OP/BP 4.36) [] [X] Safety of Dams (OP/BP 4.37) [] [X] Projects in Disputed Areas (OP/BP 7.60)* [] [X] Projects on International Waterways (OP/BP 7.50) [] [X] 15 ANNEX 1: RESULTS FRAMEWORK AND MONITORING Project Development Objective (PDO): The PDO of the project is to enhance the capacity of selected communities to increase their resilience to the impacts of climate change. Description Cumulative Target Values** Responsibility (indicator Core PDO Level Results Unit of Data Source/ definition Baseline YR 1 YR2 YR 3 YR4 YR 5 Frequency for Data Indicators* Measure Methodology etc.) (FY13) (FY14) (FY15) (FY16) (FY17) Collection Indicator One: Semi- Progress M&E unit in - Clear roles & % of 5% 20% 40% 50% 60% 70% annually report PKSF responsibilitie Community mechanisms commun- s assigned established and functioning in ities Data Sub-project - Ability to selected communities to sources: NGO generate respond effectively to specific Capacity & internal climate risk vulnerability resources assessment; - Common risk criteria for assessment mechanisms & mapping; for specific CC climate risk investment plan Indicator Two: % of 5% 20% 40% 50% 60% 70% Semi- Progress M&E unit in Proof of communi annually report PKSF applied Communities to have applied ties knowledge & sustainable adaptation Sub-project access to practices to address specific NGO information climate change risk 16 Indicator Three: %of the Semi- Progress M&E unit in Based upon sub- 0 20% 50% 75% 75% annually report PKSF baseline Sub-grants implemented in the grants collected by selected communities are Sub-project NGO & assessed to have achieved the NGO PKSF & targeted objectives impact evaluation team INTERMEDIATE RESULTS 1. Intermediate Result (Component One): Community Climate Change Fund management: A functional financing mechanism for community-based adaptation sub- projects established 1. Intermediate Result Number of 0 24 40 40 40 40 Semi- Progress M&E PKSF indicator One: sub- annually reports projects Number of community-based funded in adaptation sub-grants drought awarded. (8), flood (16) and saline (16) regions Intermediate Result indicator % of sub- 0 40% 60% 80% 80% 80% Quarterly M&E report; M&E unit in Two: projects Field visit PKSF; PO % of PIPs with awarded sub- report of projects found fully compliant PO; with policies and procedures Internal Auditor agreed under CCCP. audit report Intermediate Result indicator %of the Semi- Progress M&E unit in Three: sub-grants 0 40% 60% 75% 80% 80% annually report PKSF Sub-grants have been disbursed to the NGOs in a timely manner. Intermediate Result (Component Two): Knowledge management, M&E and Capacity Building: Systematic process of sharing lessons and incorporation of best practices into the design and implementation of interventions is operationalized. A robust M&E system to ensure effective monitoring of sub-project outcomes at the community and project levels operationalized. 17 Intermediate Result indicator % of PIPs 0 50% 70% 80% 80% 80% Annually Evaluation M&E unit of One: sheets at the PKSF; PIPs with awarded sub- annual Training & projects have identified a list information community of lessons learned during sharing development annual workshops for use in workshops officer their adaptation initiatives Intermediate Result indicator % of PIPs 0 50% 70% 80% 80% 80% Annually Evaluation M&E unit of Two: sheets at PKSF; Percent of PIPs report best annual Training & practices to PKSF and other information community stakeholders sharing development workshops officer Intermediate Result indicator Report for 0 0 3 3 3 3 Annually Annual Natural Three: each report resources Toolkit & guidelines prepared vulnerable management for community-based climate region officer change adaptation M&E unit of PKSF Intermediate Results Indicator 15 0 5 10 15 20 20 Progress M&E unit of four: report PKSF Number of inter-community visits Intermediate Results Indicator % of PIPs 0 50% 70% 80% 80% 80% Quarterly Progress M&E unit of five: report PKSF Sub-project has conducted a baseline study, vulnerability and risk assessment and investment plan Intermediate Result (Component Three): Project Management - A Project Management Unit (PMU) established to administer project funds and to monitor implementation performance of activities. Intermediate Result indicator Core staff 0 12 12 12 12 12 Quarterly Activity Project One: recruited report Coordinator, PMU has the required staff, Deputy equipment, office space & As per Managing manuals equipment 0 60% 80% 80% 80% 80% Director list 18 M&E unit of Office PKSF rooms in 0 60% 80% 80% 80% 80% PKSF Intermediate Result indicator Reports 0 Inception Activity Activity Activity Activity Ongoing Activity M&E unit of Two: PKSF produces regular prepared: report (1) (4), (4), (4), (2), reports, PKSF Activity (quarterly), Progress Activity Activity Progress Progress Progres Progress Progress (bi-annually, annually) and (18), (), (2), (2), Mid- s (2), (1), reports, Impact evaluation reports Progress Progress Outcome term Outcom Impact Third Party (MTR and Project (9), Impact (2), monitor evaluation e evaluation Outcomemo Completion); Third Party eval. (2) Outcome (1), (1) monitor (1) nitoring Outcome monitoring monitori (1), reports, (Annual) ng (1) Impact evaluation reports 19 Annex 2: Detailed Project Description Bangladesh: Community Climate Change Project 1. The Community Climate Change Project introduces a new and innovative approach to finance community-based adaptation interventions in selected climate-vulnerable areas by building the institutional capacity of PKSF to administer a climate change adaptation fund. The proposed project consists of three components: (i) a multi-donor climate change adaptation trust fund, which would provide sub-grants to NGOs to administer community-level sub-projects; (ii) knowledge management; and (iii) overall project management, M&E, and capacity building. Since most adaptation interventions to date at the community level have been very small, scattered and uncoordinated, the project would adopt a framework approach for the identification of scalable community sub-projects, using transparent criteria, to meet the objectives of the project. The details of the project components are described below. NGOs are defined, for purposes of the CCCP, as in OD 14.70: "private organizations that pursue activities to relieve suffering, promote the interests of the poor, protect the environment, provide basic social services, or undertake community development." Component 1: Community Climate Change Adaptation Fund (US$10.40 million) 2. This component would establish a US$10.40 million fund to finance community-based climate change adaptation sub-projects implemented with the assistance of NGOs. The fund would be managed by PKSF through a separate PMU, for which the cost of staffing, equipment and operational support would be covered under Component 3. 3. PKSF will invite NGOs to submit sub-project proposals to address climate change impacts in three vulnerable zones: (a) salinity-affected coastal areas; (b) flood-affected char- lands and river basins; and (c) drought-affected or rainfall-scarce areas. Each sub-project must be located within one of these vulnerable zones (a list of upazilas in these zones is in Table 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. Each approved sub-project would be funded with a sub-grant of US$20,000 up to US$1 million. All sub-grant disbursements must be completed three months before the completion date of the CCCP. 4. Any NGO receiving sub-grants must demonstrate how its community-level sub-project will contribute to advancing the skills and knowledge required for the specific target community to adapt to extreme climate variability and climate change. The NGO must have an established presence in the region where the sub-project will be implemented, and the sub-project would preferably build on the foundation and social capital of other projects that the organization is already implementing. The sub-projects would involve community leadership and local governments, and ensure gender sensitivity. Emphasis would be on transparency, monitoring and evaluation, information capture, and learning to ensure the sustainability of sub-project activities and their replicability in other parts of Bangladesh. 20 Component 2: Knowledge Management, M&E and Capacity Building (US$ 0.44 million) 5. Since both climate change and community-based adaptation are new and evolving areas, this component would promote the sharing of lessons and best practices among the participating NGOs, the wider NGO community within Bangladesh, and regional and global forums. This component would also support a structured learning process, including inter-community visits, aimed at capturing lessons and incorporating best practices into the design and implementation of interventions related to climate change adaptation. 6. The CCCP is expected to generate a substantial amount of information and knowledge. The implementing NGOs will document, analyze, interpret and share their knowledge and experiences. Since community-based adaptation programs do not have much precedence, it is important to ensure that the information, knowledge and experiences emerging from the sub- projects benefit as many people as possible. In order to mainstream the experiences, the project will undertake the following:  In addition to obligatory documentation during the monitoring process, the participating NGOs will be encouraged to be part of a network, and to lead the network secretariat on a rotating basis. The secretariat will facilitate networking activities; maintain a website and database, to which member NGOs will contribute; and organize national-level issues- based workshops and major learning events. The NGO leading the secretariat will provide the logistics, office space, HR and information management support.  The information and knowledge generated by the CCCP will be available for further research and regional and global forums. CCCP will be a highly IT-supported initiative. The NGOs will post their research and progress reports online following a standard system. The PKSF will establish a separate database, with information organized by issue and vulnerable zone. The M&E unit of PKSF will periodically update this information and make it available to interested researchers in a user-friendly form.  CCCP will organize a yearly retreat with POs to share the core learning emerging from the sub-projects. CCCP will also encourage each NGO to organize a yearly meeting to discuss monitoring reports, lessons learned, and recommendations for the future. PKSF will subsequently organize a retreat inviting one representative from each NGO to share his/her experiences. Proceedings of NGO and PKSF-level workshops will be posted on the CCCP website. 7. Technical Assistance will be provided to (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/sub-project levels, and by an independent third party, who shall conduct annual outcome monitoring; and Impact evaluation at mid-term and project completion of the performance of the financing mechanism, 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. 21 Component 3: Project Management (US$1.66 million) 8. This component would finance technical assistance to: (a) establish the PMU within PKSF and hire/train staff to manage the trust fund and monitor the implementation of sub- projects; as well as finance the PMU’s operating costs, procurement, and other expenses related to the administration of project funds; and (b) build the technical capacity of PKSF to appraise climate change adaptation sub-project proposals submitted by NGOs, and to operationalize the procedures for fund management outlined in the Operational Manual (see Annex 3 for details). 9. Detailed estimated cost of the various project components are in Table 1 and the list of upazilas to be covered by the project are in Table 2 below: 22 Table 1 COMMUNITY CLIMATE CHANGE PROJECT SL Components Proposed ($ USD) 1.0 Component 1. Community Climate Change Fund 1.1 Funds Available for Sub-Grants (incl. for 10,400,000 Innovation) 1.2 COMPONENT 1 SUB-TOTAL 10,400,000 2.0 Component 2. Knowledge Management 2.1 (a) Workshops 2.10 Workshops 15,000 2.11 Launching workshop 4,000 2.12 Completion workshop 5,000 2.13 Travel to International conferences 50,000 2.2 (b) Communication & Knowledge management 2.21 Communication materials productions 48,000 2.22 Web development (firm) 15,000 2.23 Knowledge center materials (books, 7,000 document etc.) 2.24 Intra-project travel & learning 30,000 2.3 (c) Monitoring & Evaluation 2.31 M&E officer 80,000 2.32 MIS officer 50,000 2.33 MIS consultant 0 2.34 Travel for PIP activity, appraisal, 100,000 grievance redress and outcome monitoring 2.35 Third party monitoring 32,000 2.4 (d) Capacity building 2.41 Training of CCCP team 5,000 2.42 Resource person (s) 1,500 2.5 COMPONENT 2 SUB-TOTAL 442,500 3.0 Component 3. Project Management, M&E and Capacity Building Monitoring system sub-component 3.1 3. (a) TA for PKSF M&E 23 3.10 External audit 13,000 3.11 3. (b) TA for grievance redress system 0 3.12 Training 12,000 Project management sub-component 3.13 3 (c) Office Rent 117,000 3.14 3. (d) Office equipment 62,000 3.15 3. (e) Administrative costs 315,000 3.16 3. (f) Staffing 3.16.1 Project Coordinator 201,000 3.16.2 Sr Accounts & Financial Officer 81,000 3.16.3 Accounts & Financial Officer 41,000 3.16.4 Program officers (3) (Drought, flood, 242,000 coast) 3.16.5 Program officer: Environment & Natural 80,000 resources management 3.16.6 Program Officer: Training & 80,000 community/social development 3.16.7 Program officer: Communication and 80,000 Knowledge Management 3.16.8 Administration officer/Deputy Project 100,000 Coordinator 3.16.9 Office assistant 30,000 3.16.10 Secretary 30,000 3.16.11 Support staff (messenger) 60,000 3.16.12 Dispatch/Reception associate 20,000 3.17 Technical reviewer 12,000 3.21 3 (g) Communications for call for proposals 3.21.1 Advertising 6,500 3.22 Contingency 75,000 3.23 COMPONENT 3 SUB-TOTAL 1,657,500 4.0 TOTAL 12,500,000 24 Table 2 Climate Risk District Upazila 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 Kishoreganj Nilphamari Sadar 25 Annex 3: Institutional and Implementation Arrangements Bangladesh: Community Climate Change Project Overall Institutional Arrangements 1. Implementation of the proposed project will involve the following Government institutions: • Ministry of Environment and Forests (MOEF) will be the coordinating ministry on behalf of the Government for this project; • Bangladesh Climate Change Resilience Fund (BCCRF) will provide the funds for this project as well as exercise broad fiduciary controls and provide strategic guidance through its Governing Council and Management Committee; • Palli Karma-Sahayak Foundation (PKSF) will receive the funds from BCCRF and be responsible for implementation of the project. BCCRF 2. Bangladesh Climate Change Resilience Fund (BCCRF) is a partnership among the Government of Bangladesh, World Bank, and other development partners to address the impacts of climate change. The trust fund was established in May 2010, with financial support from Denmark, the European Union, Sweden, Switzerland, and the United Kingdom. BCCRF will enable the Government to channel more than US$125 million in grant funds to build resilience to the effects of climate change. 3. The objective of BCCRF is to support implementation of the Bangladesh Climate Change Strategic Action Plan (BCCSAP). The Government leads the management and implementation of BCCRF. On behalf of the contributing development partners, and in consultation with the Government, the World Bank ensures that the BCCRF meets due diligence requirements and is implemented efficiently. 4. BCCRF has a two-tier governance system: (a) a Governing Council, which provides overall strategic direction and guidance to BCCRF and ensures its alignment with the BCCSAP; and (b) a Management Committee, which is responsible for developing a work program, ensuring that the BCCRF is implemented in line with the agreed implementation arrangements, and considering grant requests submitted by various line ministries and other eligible institutions. 5. Both the Governing Council and the Management Committee are chaired by the Government. A Secretariat, based in the MOEF, is responsible for providing support to the Governing Council and Management Committee, and for providing advocacy, communication and coordination support to all agencies implementing the activities funded by BCCRF. 6. The Governing Council is a high-level committee chaired by the Minister of MOEF and comprising the Ministers of Finance, Food and Disaster Management, Foreign Affairs, and Water Resources; Secretaries from MOEF’s Economic Relations Division, MOF, and Ministry 26 of Planning; two representatives from contributing development partners; two representatives from civil society, and the Country Director of the World Bank as an observer. The primary responsibilities of the Governing Council are to provide advisory guidance on the fund’s strategic goals and alignment with BCCSAP; establish grant criteria; oversee overall management and utilization of BCCRF; approve projects to be funded by BCCRF; and review the achievement of results envisaged by the BCCRF. 7. The Management Committee is a small technical committee chaired by the Secretary (MOEF). It includes two other representatives from the MOEF (one from the Economic Relations Division and one from the Planning Commission); two representatives from contributing development partners; one from the World Bank, and one from civil society. 8. The primary responsibilities of the Management Committee are to review and endorse the BCCRF work program and budget allocations; carry out a detailed review of grant requests submitted by the Secretariat; ensure that grant requests submitted are in line with the agreed policies and procedures; and review and endorse the reports prepared by the BCCRF Secretariat for submission to the Governing Council as well as for public dissemination. 9. The World Bank is responsible for ensuring adequate fiduciary management, transparency, and accountability in executing BCCRF, and that the funded projects are implemented with due regard to economy, efficiency and effectiveness. The World Bank also provides some analytical and advisory support for implementation of BCCSAP via its role in BCCRF. 10. An Implementation Manual detailing the governance and operational mechanism for BCCRF was agreed among the Government, development partners and the World Bank. The BCCRF became operational with the first Management Committee meeting held in February 2011. PKSF 11. PKSF was established by the Government in 1990 as the apex organization with the mandate for poverty alleviation through employment generation. PKSF disburses funds to microfinance institutions (MFIs) who are its Partner Organizations (POs) to implement programs designed for the poor. At present PKSF has 257 MFIs as partners and PKSF’s PO network has access to all districts in the country. PKSF has 8.6 million borrowers and has disbursed more than Taka 450 billion. 12. In its first decade, PKSF focused on strengthening program implementation and institutional development of its POs. In the second decade, PKSF shifted gear to accommodate the economic and social changes taking place in Bangladesh. In so doing, PKSF integrated non- financial services such as skills development activities into its programs. These initiatives deepened PKSF’s reach in its endeavors to generate employment among the poor. PKSF also garnered critical capability in managing crisis situations. In the face of natural calamities such as Cyclone Sidr in 2008 and Cyclone Aila in 2009, PKSF responded swiftly to address the needs of the crisis-stricken poor. Most importantly, PKSF utilized its PO network to deliver 27 grants, free clothing, and food to all corners of the region devastated by these natural disasters. As PKSF enters its third decade, its initiatives are incorporating other aspects of development, including employment generation, microfinance, health, education, and skills development. PKSF Management 13. PKSF is organized in three broad divisions as follows:  Operations Division: This division concentrates on credit and non-credit programs and projects.  Finance and Administration Division: This division deals with administration, finance, accounting, training, publications, communications, library and archives, construction and maintenance, human resources, security, and legal affairs.  Internal Audit Division: This division works to ensure transparency in all aspects of financial affairs of PKSF. The audit division is responsible for internal audit of PKSF and for ensuring regular audit of the program officers (POs) by external audit firms. Project Management Unit in PKSF 14. PKSF will establish a Project Management Unit (PMU) with suitable office facilities to manage the CCCP. A Project Coordinator (PC) will head the PMU and be in charge of overall implementation. S/he will directly report to a senior official of PKSF and be the first point of contact for the BCCRF Secretariat, the World Bank and other development partners involved in the CCCP. The PC will report to the BCCRF through the designated senior PKSF official. 15. The PMU will engage several POs to liaise with the NGOs that receive sub-grants to implement sub-projects. The number of POs will depend on the number of these NGO project implementing partners (PIPs), and the number PIPs allocated to each PO will depend on the size, geographical location and nature of the sub-projects. The POs will be the first contact points for PIPs and report to the PC. 28 Project Management Setup PKSF Governing Body BCCRF The World Bank MD/Sen official PKSF Technical Project Secretary Experts Coordinator Senior Accounts Accounts & Admin/ Deputy M&E MIS PO s &Finance Officer Finance Officer PC/Procurement Specialist Specialist Project Implementing Partners (PIP) 16. The Program Officers will have backgrounds in climate change adaptation, environment, community/social development, agriculture, water resources management, disaster management, knowledge management, and other relevant areas, and will ensure that environmental and social safeguard issues are properly addressed in all CCCP activities. In addition, an M&E Specialist dedicated to CCCP will provide technical guidance to POs on monitoring sub-project activities. S/he will stay informed about all activities under the CCCP and will report the PC (PMU). A Senior Accounts and Finance Officer, and Administrative & Procurement and Logistics Officer dedicated to CCCP will work under the technical supervision of PKSF’s Finance, Accounts and Audit Section, and under administrative guidance of the PC (PMU). 17. The PMU will also prepare a roster of technical reviewers and use their services as and when required to evaluate and appraise sub-project proposals. These technical experts will represent different thematic areas listed in the BCCSAP and different technical disciplines. Potential national/international level experts are expected to be specialized in a sector (water, health, irrigation, agriculture, aquaculture, livestock, infrastructure, etc.) relevant to climate change adaptation or experts in issues relevant to climate change (disaster management, climate and gender, community development, ecosystem management, organizational development, project management, financial management, coastal livelihoods, local governance and advocacy, etc.). Experts must have a proven record of at least 5 years in the area of development and climate change, and a relevant management/academic/research background. 18. For each sub-project proposal received, the PC will designate an evaluation team led by one of the POs, and one or more of the technical reviewers depending on the nature, scope and size of the proposal and amount of the grant requested. The PO heading each of the teams will be responsible for preparing the appraisal report and recommendations on behalf of the team. 29 The World Bank 19. The PC will keep the World Bank informed in all relevant matters and seek the Bank’s concurrence on sub-grant awards to ensure their compliance with Bank fiduciary requirements. PKSF Governing Body 20. The PC will submit sub-grant awards for “no objection� by the World Bank to the PKSF Governing Body for final approval. BCCRF Secretariat 21. PKSF will report to BCCRF Management Committee on the progress of CCCP on a semi-annual basis. PMU Office 22. Physical Setup: PKSF will establish suitable offices for the PMU with accommodation for all staff members, meeting rooms and a workshop/training room. The office will possess all modern amenities with hardware, software and telecommunication facilities for all staff members. 23. Staff Recruitment: PKSF will recruit staff members following PKSF’s standard recruitment procedures and The World Bank’s Consultant Guidelines January 2011 for selection of individual consultants supporting the PMU. All staff members will receive project- based contracts as per PKSF guidelines for development projects, and comply with the administrative and human resource policies of PKSF. 24. Selection of Technical Reviewers: The PKSF will recruit suitable technical experts to be included in the list of technical reviewers. Potential national/international experts are expected to meet the following requirements: a. Expertise in a relevant sector area (water, health, irrigation, agriculture, aquaculture, livestock, infrastructure, etc.) relevant to climate change adaptation; b. Expertise in an issue relevant to climate change (disaster management, climate and gender, community development, ecosystem management, organizational development, project management, coastal livelihoods, local governance, advocacy, etc.); c. Proven record of at least 5 years in the area of development and climate change and possess relevant management/academic/research background. 25. The PKSF will form a search committee to finalize the list of technical reviewers. The list will be updated as needed based on changing requirements. 26. Capacity Needs Assessment and Enhancement of PKSF: Since climate change adaptation is a relatively new area, PKSF will implement several initiatives to acquire sufficient knowledge and skills to manage the project efficiently and effectively. First, PKSF will recruit specialists to 30 fill the posts envisaged in the PMU. Second, PKSF will engage short-term experts to fill the apparent gaps. Third, the PKSF staff will receive training to acquire required knowledge and skills. Finally, PMU staff will network with other organizations or seek assistance from organizations such as the World Bank to access the latest knowledge in the area of climate change adaptation. PKSF may also consider training and specific technical backup support from specialized organizations, if required. Implementation Arrangements for the Community Climate Change Fund 27. Guiding Principles: CCCP will provide sub-grants to NGOs to implement sub-projects focused on community-based climate change adaptation activities. The guiding principle for the sub-grant awards is “simplicity with transparency,� so that award decisions are made in the shortest time possible and activities under the sub-grants are carried out efficiently without compromising the quality of outputs while meeting all safeguard requirements. 28. In order to achieve this, the selection of NGOs and sub-projects will be done in two phases: a Concept Review Phase (CRP), in which NGOs show that they meet a set of basic requirements to carry out sub-projects; and a Proposal Review Phase (PRP), in which the details of the sub-project are evaluated by a team of experts using a known set of criteria. The call for concept notes/proposals will begin after PKSF undertakes the following preparatory activities:  PKSF will set up the CCCP (PMU) office and recruit key staff, technical specialists and consultants, and acquire and set up the necessary office equipment and facilities.  PMU will develop a CCCP website as a part of the overall PKSF website. The website will include, inter alia, the project summary; thematic areas for support, eligibility criteria, templates for preparing proposals (in both English and Bangla); information about where to get help preparing sub-project proposals, and about the approval process and deadlines; maps showing the climate-vulnerable areas relevant to the CCCP; a list of upazilas covered by the CCCP; and other information. The website will be kept up to date at all times.  PMU will publicize the CCCP by advertising in newspapers (both Bangla and English) and other media as necessary.  PMU will develop communications material to publicize the CCCP and application procedures, in both Bangla and English, to all relevant stakeholders.  PMU will develop all necessary forms and templates (in Bangla and English) to be used by NGOs to submit sub-project proposals, at both the Concept Review Phase and the Proposal Review Phase.  PKSF will prepare guidelines for detailed evaluation of sub-project requests by evaluation teams. The guidelines will provide guidance for the PC on how to select members of the evaluation from the team of experts. The guidelines will clarify the roles 31 and responsibilities of the different evaluation team members and their expected outputs. A template will guide the team members on how to comply with evaluation requirements. Necessary training on how to carry out evaluations will be provided for PMU staff.  PKSF will formally launch CCCP through a public event, to which high-level representatives of all relevant stakeholders (NGOs, government agencies, donors, researchers, experts, media) will be invited. Concept Review Phase. Submissions for the Concept Review should provide the following:  A brief description of the sub-project (maximum 2 pages) showing how it qualifies as an “adaptation� activity and how it addresses at least one of the six thematic pillars of the BCCSAP;  Location of the sub-project in one of three vulnerable zones: salinity-affected coastal areas; flood-affected char-lands and river basins; and drought-affected or rainfall-scarce areas. A list of upazilas in these three vulnerable zones (in Annex 2) will be available on the CCCP website;  The NGO must be currently registered with an appropriate Government authority, and legally able to undertake the proposed activities;  NGOs requesting funds must prove that they have had an established presence in the target area for at least three years, and the proposed sub-project should ideally build on the foundation and social capital of other projects that the organization is already implementing;  The applicant NGO must provide evidence that it has been active in similar activities for the last five years; and must submit annual reports and audit reports for the last three years;  The applicant NGO must have an annual budget of at least US$150,000 (approximately 1 crore taka) for the last three years;  The NGO must provide detailed information on its organizational structure, staffing and staff responsibilities; The Concept Review Phase will establish which NGOs are eligible based on these criteria and a review of the concept note. Detailed proposals will only be requested from NGOs determined to be eligible. NGOs declared eligible will be notified within one (1) month of their submission so that they can start preparing their detailed proposal. The CCCP PMU will periodically hold orientation sessions to provide guidance to NGOs in the preparation of their detailed proposals. There will be automatic disqualification of both evaluators and NGOs if there are conflicts of interest. Proposal Review Phase will consist, inter alia, of the following steps: 32  Once an NGO has passed the Concept Phase, it will start preparing the detailed proposal prescribed by the CCCP. Additional help from the PMU in terms of guidance in the application process will be provided through formal workshops. The proposals must comply with the environmental and social thresholds are established in the environmental and social management frameworks.  The detailed proposals will be submitted in prescribed format and templates, together with any required annexes. The proposal can be in either Bangla or English. Receipt of the proposal will also be posted on the CCCP website. Proposals will be evaluated in the order received, and sub-projects will be selected and sub-grants awarded until funds in the CCCF are fully committed.  After the proposals and attachments are received, the PC will appoint an evaluation team to evaluate them based on the following criteria (which will be refined as the project progresses): Criteria Max Score Recd. 1 Justify how the project fits one of the pillars of BCCAP. 10 2 How will the sub-project enable communities to adapt to the potential climate 20 vulnerability in the target area? How will it involve the community and enhance the capacity and knowledge of the community to adapt? Extent of community contribution to the project. 3 Is the sub-project scaling up an ongoing successful adaptation intervention, or 10 enhancing an ongoing intervention to include adaptation? Tools such as Vulnerability and Capacity Analysis (VCA) may be utilized. 4 Detailed sub-project cost (overhead cost should not exceed 10%), an 10 implementation plan; how sub-grant funds will be used by quarter and over what period of time. 5 Description of the organizational arrangements and staffing, and their relevance to 5 the proposed activities. 6 Arrangements for handling financial management and procurement-related issues. 10 7 Arrangements for handling environmental and social issues. 10 8 Arrangements for monitoring and reporting of sub-project activities. 10 9 Linkage of the sub-project with local government systems and programs. 5 10 How will the sub-project activities be sustained? 10  A proposal must score at least 70 percent in order for the grant request to be approved. The NGO must also fulfill criteria 1, 2 and 3, and its overhead cost must not exceed 10 percent. The PO will attach a short note on the assessment sheet justifying the approval or rejection. Information about any proposal not funded will be available on the website, with the justification. No separate letters will be issued. Decisions on acceptance or rejection of proposals will be made within a maximum period of two (2) months from the date of receipt of the proposal. The leader of the appraisal team will submit the evaluation report and recommendation along with the aggregate score to the PC for further action.  In most cases, the evaluation team will make a decision based on the proposal. If the proposal does not include all the information required, the NGO may be contacted to 33 furnish additional information. In other cases, the applicant organization may be asked to make a presentation at the PKSF office to clarify its proposal. All proposals will also be appraised in the field.  The PC will present the recommended proposals to the World Bank for its “no objection,� and to the Managing Director of the PKSF Governing Body for approval.  If the Governing Body’s decision is “other than approved,� PC will negotiate with the applicant organization for resubmission of the proposal for re-appraisal in view of the observations made by the Governing Body. The “not approved� decision is final and will be communicated to the applicant, with reasons for the decision.  Once a proposal is approved, a draft sub-grant agreement between the PKSF and the implementing NGO will be subject to review by the World Bank. Grant Implementation and Monitoring Phase  Once the sub-project is approved by PKSF Governing Body, the PC will arrange a meeting of the Managing Director or any other designated senior official of PKSF with the Chief Executive Officer of the selected NGO to sign the sub-grant agreement. A check based on the first six months of the financial plan (two quarters) will be given to the NGO as the first disbursement after signing of the agreement.  After the signing of the agreement, the NGO would start implementing the sub-project in line with the work plan, operational manual, and all other terms and conditions of the grant agreement. The work plan will be reviewed every three months with the monitoring staff of the PMU. An inception report must be submitted within three months and include the work plan, and baseline data on the target community. Results Monitoring and Evaluation  The project will be monitored at three levels – (1) achievement of outcome of the project, (2) the performace of PKSF in the establishment and implementation of the sub-grant financing mechanism, and (3) the performance of NGOs in the implementation of the sub-grants. An annual Third Party monitoring; and an mid-term and completion impact evaluation will be conducted to determine the progress towards the achievement of the project development objectives. PKSF will be responsible for setting-up a functioning Project Management Unit (PMU), the sub-grant mechanism, and ensuring effective implementation of the fiduciary aspects throughout the project including environmental management, social assessment and management, financial management, and procurement management. A third party monitoring will be conducted as frequently as necessary, to assess the effectiveness of PKSF as the implementing agency and monitor the sub-projects implemented by NGOs for adressing the climate risk for each of the selected regions. 34  Each sub-project under implementation will be subject to monitoring by both the NGO and PKSF. A detailed M&E manual, which has been prepared, consistent with PKSF’s overall results-based monitoring system, will guide the monitoring practices of PKSF and the grant recipient.  Monitoring under CCCP will have three functions. First, it will help CCCP to ensure that sub-grant recipients deliver the agreed outputs, which would indicate that the resources are being used efficiently for the proposed activities. Second, monitoring will establish proper documentation of the implementation process and achievements at different levels (outputs, outcomes and impacts). Third, monitoring will help capture learning from the process. Since adaptation experience is highly contextual, documentation of learning under different contexts will add to the knowledge base for future actions. In short, the role of accountability is significant in case of outputs, whereas learning becomes a core issue of monitoring at the level of outcomes, and impacts and the level of achievements.  Tasks and Duties of Sub-Project Monitoring Officer: Sub-grant recipients will employ a dedicated Sub-project Monitoring Officer (SMO) who will report to the Chief Executive or senior official not directly entrusted with implementation of the sub-project. The sub- project monitoring officer will implement the Monitoring Framework as envisaged in the sub-project proposal and will produce quarterly activity monitoring reports based on the agreed-upon Activity to Output Monitoring (ATOM) outlined in the Monitoring and Evaluation Manual. The SMO will undertake semi-annual outcome-level monitoring based on the agreed Outcome Assessment Sheet (OAS), and annual impact-level monitoring based on the agreed Impact Assessment Sheet (IAS), which will be prepared taking indicators of Impacts and Outcomes into account. S/he will also ensure that the information is posted on the PKSF website.  Task and Duties of PKSF Program Officer (PO): Based on the monitoring information available to PKSF, the relevant PO will seek clarifications or explanations or learning regarding any deviations in the monitoring data. The PO will undertake monitoring visits quarterly to validate the monitoring already undertaken by the sub-grant recipient. Each PO will prepare his/her own monitoring report semi-annually and make recommendations on the next disbursement.  Tasks and Duties of Central M&E Unit of PKSF: The M&E unit of PKSF will undertake quality control of the monitoring activities of the POs, and provide capacity building wherever necessary. It may also organize training on monitoring for staff of the implementing NGOs. The central M&E unit of PKSF will assist the POs in summarizing the monitoring reports of the NGOs under different pillars or themes, and prepare semi- annual progress reports and annual reports for review by the PC.  External Monitoring and Evaluation of CCCP: CCCP will be subject to external impact evaluation compared against baseline data, at mid-term and project completion. PKSF will also contract an external third party monitor to prepare annual outcome monitoring reports and monitor sub-projects if required. PKSF and the World Bank will jointly formulate the terms of reference for the external evaluation. 35 Financial Management, Disbursement and Procurement Financial Management 29. Overall, the residual financial management risk for the project is assessed as “Substantial.� While the systems in place for internal control, accounting and bookkeeping, internal and external audits in PKSF are adequate, additional staff (a Senior Accounts and Finance Officer and an Accounts Officer) will be recruited to mitigate the residual risk. 30. PKSF, having long experience in managing projects supported by the Bank and other development partners, has developed efficient FM and internal control systems. PKSF has an established finance division headed by a Deputy Managing Director for Finance and Administration. In order to monitor the activities of it partner organizations, it also has in place a properly staffed internal audit cell headed by a General Manager who directly reports to the Managing Director of the organization. PKSF has built up a system and capacity for disbursing fund to POs based on efficient review procedures in coordination with field level monitoring. A private audit firm carries out external audit of PKSF, and will continue to do so for the PKSF’s financial management of the CCCP. 31. Internal Control: The implementing NGOs will receive disbursements according to the following criteria and processes:  PKSF will enter into a sub-grant agreement with each NGOs that states the sub-project plan, and the terms and conditions for disbursement of funds against sub-project activities.  The first disbursement to each NGO will be made as advance against the sub-project plan. PKSF and the NGOs may also opt for reimbursement of expenditures after achieving agreed-upon sub-project milestones.  The subsequent funds will be released to the each NGO subject to PKSF’s receipt of a Statement of Expenditures (SOEs) along with evidence of successful completion of agreed-upon milestones.  PKSF will undertake the due diligence in checking and verifying the claims of the NGOs. NGOs will report to PKSF on financial and physical progress on a monthly basis.  Each NGO will open and maintain a separate bank account for the sub-grant. PKSF shall disburse sub-project funds only to that account.  The initial advance paid by PKSF to each NGO will be accounted for as advance in the NGO’s books of accounts and financial reports, until actual expenditures are reported by the NGO and verified and accepted by PKSF. Only actual expenditures are reimbursable by PKSF to NGOs, and from the climate change trust fund to PKSF’s designated account. 32. Disbursement and Funds Flow: The funds for CCCP will flow through a Segregated Designated Account (DA) in the form of Convertible Taka Special Account (CONTASA) to be opened by PKSF in a commercial bank acceptable to the World Bank. The disbursement will be report based; i.e., advances to the DA will be made on submission of quarterly Interim Un- audited Financial Reports (IUFRs), including a forecast of projected expenditures for the next two calendar quarters. Further advances as required would be made to the DA on the basis 36 updated expenditure forecasts for the subsequent two quarters. The amounts spent from the DA on eligible expenditures will be documented as project expenditures on the basis of claims for documentation in the IUFRs, and the advances to the DA will be adjusted accordingly. 33. Ceiling of advances to the Designated Account is variable, based on the financial forecast up to two quarters. Advances will be adjusted upon receipt of documentation of expenditures on sub-projects and on appropriate certificate of completion of sub-projects. 34. Payments from PKSF to each NGO will be made on the basis of the terms and conditions specified in the sub-project agreements. Funds will flow to the NGOs on completion of progress milestones, after PKSF receives a Request for Funds along with a copy of the NGO’s bank statement, evidence of completion of milestone(s) and expenditures reports. 35. Staffing: PKSF is experienced in handling donor-funded projects and their FM staffs are well equipped to handle such funds. But PKSF will need additional FM staff to manage and carry out day-to-day financial activities of the project. The FM staff will be appointed with Terms of Reference acceptable to the Bank. Authority, responsibilities and reporting line will be clearly defined in the TOR to enable the FM team to ensure smooth fund management, reporting, and accountability of the project’s financial management. In order to ensure effectiveness and continuity of financial management functions and disbursement, the PKSF would be required to recruit the following staff members by the dates shown in the table below. Financial Management Action Plan Position Consultant/Staff No. Of Staff Actions Needed Date Senior Accounts Consultant 1 Agree on TOR with IDA and August 31,2012 and Finance publish REOI. Officer Select the person, and By negotiations Appoint From the date of project effectiveness Accounts Officer Consultant 2 Agree on TOR with IDA and August 31, 2012 (AO) publish Request for Expression Of Interest (REOI). By Select the person, and negotiations Appoint From the date of project effectiveness (1 out of 2 AOs and, the 2nd AO may be recruited in 2nd year based on workload) 36. Project budget: Although PKSF will not need to have a Development Project Proposal (DPP) or allocations under Annual Development Plans, it will be required, for sound financial management, to prepare an annual budget for the project in alignment with the procurement and 37 implementation plan. Actual expenditures of the project will be compared with the budget and variance analysis will be done to improve the overall effectiveness of CCCP. 37. Books of Accounts and Financial Reporting: The accounts of PKSF are prepared in accordance with International Accounting Standard (IAS) as adopted by the Institute of Chartered Accountants of Bangladesh (ICAB), on a going-concern basis under Generally Accepted Accounting Principles. PKSF’s accounts are maintained on accrual basis under historical cost convention. The accounting manual of PKSF has been consistently followed for preparation of software-based final accounts. 38. The PKSF will maintain separate books of accounts and registers and prepare annual financial statements for the project, comprising: (a) Comprehensive Income Statement; (b) Statements of Cash Flow; (c) Statement of Financial Position; (d) Notes to the Account following IAS/IFRS. In addition, PKSF shall also prepare and submit to the World Bank quarterly IUFRs showing the project expenditures incurred in the reporting and the past quarters and cash forecast for next two quarters along with fund reconciliation statements in accordance with the Bank procedures. 39. The NGOs will send monthly Statements of Expenditures (SOEs) within 15 days of the end of each month to the PKSF, which will collate all SOEs within 30 working days of the end of each month. The PKSF will submit quarterly IUFRs to the World Bank for the entire project not later than 45 days after the end of each quarter. The PKSF will use its computerized accounting system to account for all transactions of the projects incurred by PKSF and to incorporate expenditures incurred by the NGOs on sub-projects. PKSF’s annual financial statements will incorporate an additional disclosure on income and expenditure, receipts and payment and financial position of the overall CCCP along with other notes and relevant information. 40. Internal Audits: In order to monitor the activities of its POs, PKSF has in place an internal audit cell headed by a general manager, who is supported by three mid-level and nine junior-level officers. PKSF will, in consultation with the World Bank, prepare an annual audit plan to carry out annual internal audit on the project/sub-project activities and expenditures incurred by PKSF itself and the NGOs to review the compliance, accountability and transparency of the expenditures and the process, and assess the relevance of the expenditures incurred for the purpose intended. The semi-annual internal audit report on the project, comprising observations and recommendations, will be furnished to the Bank not later than 90 days from the end of an audit period. 41. External Audits: PKSF appoints a reputed private auditing firm as selected by PKSF’s General Body in Annual General Meeting for each financial year, in accordance with the Articles of Association of PKSF. The audit is performed as per approved terms of reference. Financial statements are audited annually in accordance with appropriate auditing standards (ISA) consistently applied by independent auditors. The entity financial statements of PKSF will adequately reflect the project transactions. PKSF will prepare separate project financial statements that will also be audited by the same auditor that audits the PKSF entity financial statements. The auditor will express its opinion on the truth and fairness of the financial 38 statements of the project. The PKSF will submit the audited financial statements of the entity and the project no later than December 31 of each year. 42. Supervision Plan: The initial supervision will focus on compliance with all agreed actions, terms and conditions and identify any FM or disbursement issues in project implementation, especially on sub-project grants, and agree on remedial measures. BCRRF Financing The total project cost is US$12.5 million. The following table shows the financing of the trust fund under different categories. Allocation of MDTF Grant Proceeds Description Project Cost Financing (US$) (% including taxes) 1. Sub-grant 10,400,000 100% 2. Goods, works, consulting services, non- 2,100,000 100% consulting services and incremental operating costs Total 12,500,000 43. The term “Incremental Operating Costs� means the reasonable costs incurred on account of the project for office utilities, office supplies and stationeries; office rental; unforeseen / petty requirements for printing and publication; operations and maintenance of vehicles (fuel, repairs, insurance, etc.); rental of vehicles and equipment; project-related events such as training, seminars and workshops; bank charges; advertising costs; salaries and contractual allowances of contracted project staffs; and any other operational cost agreed with the Bank; and excluding salaries of the recipient Government’s civil servants. 44. Retroactive financing: The project is likely to incur some expenses before signing of the Grant Agreement under Category 2 following the Bank’s Procurement and Consultant guidelines. Such expenditures incurred not prior to August 01, 2011 will be reimbursed to PKSF from the trust fund, up to the ceiling of US$100,000 under retroactive financing. Procurement 45. Country Procurement Environment: The Country Procurement Assessment Report (World Bank, 2002), identified inadequate public procurement practices as major impediments to the implementation of development projects. The Government is implementing a procurement reform through two back-to-back Public Procurement Reform Projects (PPRP and PPRP-II). The Government created the Central Procurement Technical Unit (CPTU) in 2002; approved and issued the Public Procurement Act (PPA) 2006; and issued Public Procurement Rules (PPR) in 2008, with associated implementation procedures, including streamlined procurement approval process, delegation of financial powers, and standard set of documents 39 for procurement of goods, works and services. The PPA and the PPR have been effective since January 31, 2008. With some exceptions, the PPA and PPR contain good international practices, including: (a) non-discriminatory selection of bidders; (b) wide advertising of procurement opportunities; (c) public opening of bids in a single location; (d) disclosure of all contract awards above a specified threshold on the CPTU’s website; (e) clear accountability for delegation and decision-making; (f) annual post-procurement audit (review); (g) sanctions for fraudulent and corrupt practices; and (h) review mechanism for handling bidders’ protests. Under PPRP, in order to build procurement management capacity, CPTU, in collaboration with the International Labour Organization (ILO) and local institutes, has developed a critical mass of 25 national trainers, and provided training to about 1800 staff of different public sector entities up to September, 2007. PPRP II, which has been under implementation since September 2007, is focusing largely on implementation and monitoring at key sectoral agencies, capacity development, monitoring and management of procurement reforms, introduction of electronic government procurement (e-GP), and behavioral change and social accountability. As of end April 2012, under PPRP-II, about 2,100 officials had received three weeks of procurement training. 46. Findings on Procurement Assessment: An assessment of PKSF has been carried out to evaluate its capacity to implement the project and the adequacy of its systems, and to assess procurement-related risks. A PMU will be formed and headed by a project coordinator and staffed with PKSF officials and consultants. This assessment reveals that although PKSF follows strict rules and procedures for financial transactions, it has limited experience with procurement of goods and services under World Bank-funded projects. This assessment reveals that though procurement volume under the project is low, with PKSF following Bank Guidelines and Government’s PPA/PPR, the fiduciary environment remains risky. The risk rating in this regard is “Substantial.� PKSF will be required to hire a procurement consultant to work in the PMU (see para. 52). 47. Measures that have been completed during project preparation include: (a) confirmation by PKSF of the names and designations of the procurement focal point (PFP), and one back-up PFP; (b) finalization of initial procurement plan covering the whole period of implementation; (c) agreement on Procurement Risk Mitigation Plan (PRMP) format and agreement with PKSF on submission of PRMP to the Bank on an annual basis. 48. Measures that have been completed during project preparation include: (a) confirmation by PKSF of the names and designations of the procurement focal point (PFP), and one back-up PFP; (b) finalization of initial procurement plan covering the whole period of implementation; (c) agreement on Procurement Performance Improvement Plan (PPIP) format and agreement with PKSF on submission of PPIP to the Bank on an annual basis. 49. Measures to be completed by PKSF by credit effectiveness include hiring a Deputy Project Coordinator with procurement expertise to support the agency on the procurement activities under the program and guide the PFP and PMU on procurement issues for the whole duration of the program, if required. 40 50. Measures to be taken during project implementation include: (a) submission by PKSF of an annual PPIP status report to the Bank starting from 12 months after credit effectiveness; (b) mandatory attendance by the Deputy Project Coordinator at tender/ bid evaluation meetings to assist and guide the evaluation committee in the evaluation process; (c) use of the Bank’s standard format for evaluation reports on all contracts; (d) provision by the Bank of procurement orientation or training workshops as and when required for PKSF staff; (e) updating of the procurement plan by PKSF at least annually or as required; (f) annual independent procurement audits by PKSF of sub-projects funded by approved competitive grants, with terms of reference of the audit cleared with The Bank; and (g) monthly procurement meetings with PKSF and the Bank to follow up progress and discuss upcoming contracts. Besides PKSF audits, Bank may conduct its own post-review of PKSF and the approved sub-projects in order to assess compliance with Bank’s Procurement/Consultant Guidelines and provisions of the Financing Agreement. 51. In addition, the following steps will be followed as part of procurement and implementation arrangements: (a) alert implementing agency (PKSF) officials/ staff about fraud and corruption issues; (b) alert bidders about fraud and corruption issues; (c) the multiple dropping of bids will not be permitted for any procurement contracts; (d) contracts will be awarded within the initial bid validity period, and the timing will be closely monitored; (e) actions will be taken against the corrupt bidders in accordance with the Bank Guidelines for International Competitive Bidding (ICB) and National Competitive Bidding (NCB); (f) all records and documents regarding public procurement will be retained, in accordance with Bank Guidelines; (g) contract award information will be published in UNDB (United Nations Development Business) online and on the agency website within two weeks of contract award; (h) PKSF will ensure timely payments to suppliers/ contractors/consultants and liquidated damages will be imposed for delayed completion; (i) the project coordinator will ensure oversight of procurement; (j) bids will be opened in public in one location immediately after the deadline for submission. 52. Guidelines: Procurement for the proposed project would be carried out in accordance with the World Bank's "Guidelines: Procurement of Goods, Works and Non-Consulting Services under IBRD Loans and IDA Credits and Grants by World Bank Borrowers" dated January 2011 (“Procurement Guidelines�); and "Guidelines: Selection and Employment of Consultants by under IBRD Loans and IDA Credits and Grants by World Bank Borrowers" dated January 2011 (“Consultant Guidelines�), and the provisions stipulated in the Legal Agreement. 53. Procurement Plan: An initial draft procurement plan has been finalized and will be approved at negotiations. The plan will cover the initial 18 months of the project and will be updated annually, always covering the next 18 months of project implementation. Any procurement of goods and works and selection of consultants shall be in accordance with the procurement plan approved by The World Bank. 54. Sub-grant beneficiaries will submit procurement plans for their respective sub-projects at the time of submission of the detailed proposals. PKSF will be responsible for ensuring adherence with the approved procurement plan. 41 The following provisions apply to all procurement carried out under the project and sub- projects. 55. Particular Methods of Procurement of Goods and Works: Except as otherwise agreed in the procurement plan, works and goods may be procured on the basis of International Competitive Bidding (ICB). Procurement of Goods and Works having an estimated value less than the ceiling stipulated in the Procurement Plan may follow National Competitive Bidding (NCB) and Shopping. Direct Contracting (Goods/Works) and Single Source Selection (Consultants) may be allowed under special circumstances with prior approval of the Bank. NCB would be carried out under Bank Procurement Guidelines following procedures for Open Tendering Method (OTM) of the People’s Republic of Bangladesh (Public Procurement Act 2006 - PPA, 1st amendment to PPA (in 2009) and The Public Procurement Rules 2008, as amended in August 2009), using standard bidding documents satisfactory to the Bank. The “Request for Quotation� document based on PPA is acceptable to the Bank for shopping. For the purpose of NCB, the following shall apply: - post-bidding negotiations shall not be allowed with the lowest evaluated or any other bidder; - bids shall be submitted and opened in public in one location immediately after the deadline for submission; - rebidding shall not be carried out, except with the Bank’s prior agreement; - lottery in award of contracts shall not be allowed; - bidders’ qualification/experience requirements shall be mandatory; - bids shall not be invited on the basis of percentage above or below the estimated cost, and contract awards shall be based on the lowest evaluated price of compliant bids from eligible and qualified bidders; and - a single-stage two-envelope procurement system shall not be allowed. 56. Methods of Procurement of Consultants’ Services: Selection of Consultants will follow the Bank Consultant Guidelines. The following methods will apply for selection of consultants: Quality and Cost-based Selection (QCBS), Quality-based selection (QBS), Fixed-budget Selection (FBS), Consultants’ Qualification (CQ), Least-cost Selection (LCS), Single-source Selection (SSS), and Selection of Individual Consultant (IC). A shortlist of consultants (firms) for services estimated to cost less than US$200,000 equivalent per contract may be composed entirely of national consultants. For the selection of these national consultants, the request for proposal document prepared based on World Bank standard request for proposals will be used. The procurement plan will specify the circumstances and threshold under which specific methods will be applicable. 57. Incremental Operating Costs: These costs will include incremental operating costs for office utilities, office supplies and stationeries, operation and maintenance of equipment and vehicles, hiring of vehicles, fuel, office rent, souvenirs, events, bank charges, advertising costs, and salaries and contractual allowances of contracted staff, but excluding salaries of Government officials. 42 58. Use of Standard Bidding and Contract Documents: For ICB procurement of goods and works, the use of the Bank’s Standard Bidding Documents (SBD) is mandatory. For procurement following the NCB method, the PMU may use a model bidding document acceptable to the Bank. For selection of all consultants, the WB’s Standard Request for Proposals (RFP), including standard contract form will be used. The Bank’s Standard Bid/Proposal Evaluation Form will be followed for submission of evaluation reports. 59. Procurement Performance Review: The Bank will monitor compliance with the requirements of its different procurement methods and performance standards on a continuous basis. As part of the project’s planned mid-term and annual review, a comprehensive assessment of procurement performance will also be carried out. Based on the review, in consultation with the Government, the Bank may revise the prior review threshold, including the procurement and selection methods. 60. Prior Review: The procurement plan shall set forth those contracts which shall be subject to the Bank’s prior review. All other contracts shall be subject to post review. The initial procurement plan agreed upon with the Borrower for the first 18 months indicates the following prior review thresholds, which will be updated annually based on the review of the capacity and performance of the implementing agency and will be reflected in the updated procurement plan as appropriate: a. Each contract for goods procured on the basis of International Competitive Bidding; b. First contract for Goods procured by PKSF following National Competitive Bidding (NCB) method regardless of estimated value; thereafter, all contracts estimated to cost US$600,000 equivalent or more, regardless of the procedure; c. Each contract for consultants’ services provided by a firm, estimated to cost the equivalent of $200,000 or more; d. Each contract for services of individual consultants, estimated to cost the equivalent of $100,000 or more and selection of individual procurement consultant, regardless of value; and e. All contracts for goods procured through Direct Contracting, and all contracts for consultants’ services procured under single source selection. f. The first NCB contract under the PMU for Goods and Works, regardless of value will be subject to prior review of the Bank. 61. Post Review: For compliance with The Bank’s procurement procedures, the Bank will carry out sample post reviews of contracts that are below the prior review threshold. Such review (ex-post and procurement audit) of contracts below the threshold will constitute a sample of at least 15 percent of the contracts to be implemented by PKSF and the NGOs implementing approved sub-projects. Environmental Safeguards 62. Applicable Environmental Category and Safeguard Polices: The proposed project will support activities in the areas of food security, social protection and health, comprehensive disaster management, infrastructure, and knowledge management in climate-vulnerable areas; 43 namely, salinity-affected coastal areas; flood-affected char-lands and river basins; and drought- affected or rainfall-scarce areas. The selected sub-projects will be funded with sub-grants ranging from a minimum of US$20,000 to a maximum of US$1 million. The proposed project may finance construction of some rural infrastructure such as water reservoirs, earthen shelters for animals, houses on higher plinth levels, rural roads, minor irrigation, etc. No long-term adverse environmental impacts are anticipated; however, actual impacts will depend on the sub- projects selected. Environmental safeguard risks for the CCCP are those typical for a rural community development project supporting small-scale basic social and economic infrastructure, and may include: (a) localized degradation or encroachment of natural habitats and associated loss of biodiversity; (b) topsoil degradation and erosion; (c) decline in water quality; (d) inappropriate waste disposal; (e) cutting of trees; and (f) potential public health concerns. 63. The project is identified as Category ‘B’ since the specific environmental impacts cannot be precisely identified before sites and types of sub-projects are selected. To avoid adverse environmental impacts and enhance environmental outcomes of the individual sub-projects, OP/BP 4.01(Environmental Assessment) has been triggered for this project. Any sub-project with severe environmental impact will not be funded under CCCP. 64. Approach to Addressing Environmental Safeguard Issues: Since the sub-projects to be financed under the CCCP will be identified during the implementation phase, it was not possible to carry out a full environmental assessment for the entire project prior to the appraisal. An Environmental Management Framework (EMF) has been prepared by PKSF describing the general baseline conditions and typical environmental impacts from different types of sub- projects during preparation, design, construction and operation. The EMF also provides the guidelines to comply with national legislation and World Bank safeguards policies, and defines the environmental requirements for each type of sub-project. In addition, the EMF has laid out the procedures for screening each sub-project at the proposal stages for potential environmental impacts, and for determining the appropriate scope of the Initial Environmental Examination (IEE). 65. The NGOs will environmentally screen all their sub-projects and submit the screening results with the proposal. PKSF will review all sub-projects at the appraisal stages for environmental compliance. Those with potential environmental impacts will be selected after proper environmental screening and Initial Environmental Examination. As mentioned in the EMF, specific mitigation measures and Environmental Management Plan will also need to be submitted with each proposal. 66. Stakeholder’s Capacity in Environmental Safeguards: PKSF has developed its own guidelines for management of their micro-credit program and Environmental Health and Safety (EHS) risks. The guidelines aim at: (a) preventing any significant adverse environmental impacts arising as a result of either individual or cumulative microenterprise activities; (b) mitigating any minor local adverse environmental impacts resulting from microenterprise activities; (c) protecting the health and safety of those workers directly involved in microenterprise activities; and (d) promoting, where possible, environmentally beneficial outcomes from microenterprise activities. However, PKSF requires capacity building support to 44 train their staff to implement the EMF and the EHS guidelines. The service of a full time focal person Program Officer (Environment) with Environmental Specialization at PMU is required. S/he will review the environmental screening, suggest the requirement of IEE, suggest any required mitigation measures, ensure that activities with significant negative impacts are not selected, and contribute in the institutional development. NGOs without environmental management experience are required to obtain the services of an environmental specialist who will be responsible for providing support at the appraisal, implementation and monitoring stages. NGO staff will be briefed on EMF during their orientation for sub-project implementation. Environmental issues will be integrated with CCCP’s grievance redress mechanism. 67. Environmental Safeguards Supervision and Monitoring: The PMU will have a program officer with environmental specialization to serve as a focal point for environmental supervision and monitoring. The field-level PKSF staff will be trained to supervise the regular implementation of the environmental management activities. Any environmental documents (screening, IEE, mitigation measure and EMP) submitted by the NGOs should be endorsed by the environmental specialist. The NGO will nominate an environmental focal person who will submit the quarterly monitoring report on environmental compliance at the sub-project preparation, implementation and operation and maintenance phases. 68. PKSF will develop its own monitoring plan to oversee environmentally critical sub- projects. PKSF’s full time focal person Program Officer (Environment) with Environmental Specialization will monitor environmental safeguard issues in the sub-projects and publish annual reports on environmental compliance. S/he will maintain a database for sub-project specific environmental screening and mitigation measures, which will be captured in CCCP’s database as well. In addition, the project’s third-party evaluation (by reputed local think-tank) will include a brief environmental audit to assess and evaluate the quality of environmental compliance of the sub-projects. 69. Consultation and Disclosure: PKSF has prepared the EMF in consultation with some potential NGOs. In addition, field visits were made to understand the environmental concerns of the community with regard to some of PKSF’s ongoing projects. Since the sub-projects under CCCP are yet to be identified, it was not possible to consult with potential beneficiaries or affected persons at this stage. However, the framework is prepared in such way that community consultations during the appraisal stage are mandatory. The EMF, in English and Bangla, will be disclosed by PKSF on its website, and hard copies will also be available at PKSF headquarters and district offices (in the sub-project areas). Advertisement requesting public comments was published in two daily newspapers (English and Bangla) and disclosed in Infoshop. The NGOs will make hard copies available at their headquarters and local offices. NGOs will also post the final versions of their EMFs and SMFs, along with summaries in Bangla, on their websites. Social Safeguards 70. The sub-project proposals are expected to include a variety of community-based climate change adaptation measures relating to (a) food security, social protection and health; (b) 45 comprehensive disaster management; (c) infrastructure; (d) research and knowledge management; (e) mitigation and low carbon development; and (f) capacity building and institutional strengthening. Some proposals might include physical works that are to be implemented on private lands, or on public lands under use by authorized/unauthorized private citizens. There could also be sub-projects on lands inhabited by small numbers of tribal peoples (TPs). Applicability of the social safeguards policies will depend upon the specific activities proposed for adaptation and the communities they involve. However, PKSF has decided to finance only those sub-projects that do not involve acquisition of private land and physical displacement of people. 71. With the restriction that adaptation activities cannot be implemented on lands obtained through involuntary acquisition or involving physical displacement of peoples, the OP 4.12 on Involuntary Resettlement has not be triggered. But the proposals may come from localities with a small proportion the TPs, which would trigger OP 4.10 on Indigenous Peoples. Although the social safeguards compliance issues would remain unknown until a proposal is actually received and reviewed, PKSF has prepared a Social Management Framework (SMF) as a guide to ensure social safeguards compliance of sub-projects. The SMF includes (a) procedures for screening; (b) tools for 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 peoples; and (e) framework for monitoring social inclusion in identification, formation and implementation of sub-projects. The SMF will apply to the CCCP as a whole and provide the basis to identify and mitigate the adverse social effects as and when caused by the individual sub-projects accepted for financing. 72. Social Screening and Selection of Sub-Project Proposals. All approved sub-projects will be screened at the appraisal stage based on the requirements of the SMF. PKSF will ensure that NGOs do not propose to undertake activities creating social safeguards impacts that cannot be mitigated within the current capacity of the NGOs, PKSF or the community. PKSF will undertake visits to the sub-project locations and the target communities and verify whether a proposal is prepared in compliance with SMF guidelines, and whether the screening results truly reflect the reality on the ground. To deal with social issues and social safeguard compliance as per SMF, PKSF and NGOs will use the following guidelines and thresholds: 73. Involuntary Resettlement: NGOs/PKSF will not undertake any physical/construction activities that:  Require acquisition of private lands by using the Bangladesh Acquisition and Requisition of Immovable Property Ordinance, 1982 (guidelines for using private and public lands are provided below);  Require involuntary contribution of private lands;  Affect private homesteads;  Require lands that are not available on “contribution against compensation� or other means not acceptable to the landowners;  Render households using public lands destitute;  Affect mosques, temples, graveyards, cremation grounds, and other places/objects that are of religious and cultural significance; 46  May significantly restrict access to common property resources and livelihood activities of groups and communities. 74. Tribal Peoples: NGOs/ PKSF will avoid any adaptation measures, including physical/ construction activities that:  Threaten cultural/traditional way of life of tribal peoples;  May severely restrict access to common property resources (forests, water bodies, etc.) and livelihood activities;  May affect places/objects of cultural and religious significance (places of worship, ancestral burial grounds, etc.). 75. Gender and Social Inclusion: NGOs/PKSF will avoid any adaptation measures, including physical/construction activities that have the risk of social exclusion, including a disproportionate impact on gender. 76. Land Availability and Resettlement: The need for use of private and/or public lands may arise in rare cases where a sub-project includes land-based activities that are a critical part of the chosen adaptation measure and have the potential to result in immense benefits. The SMF provides detail procedures and guidelines for obtaining public or private land for infrastructure in such cases. The basic guidelines for NGOs/PKSF to obtain public and private lands are as follows:  Public Lands: Where the required lands are in use by well-off persons, the NGOs and communities may persuade the users to relinquish occupancy of the lands. However, where these lands are currently used for living and/or livelihood by the poor and vulnerable, the NGOs and beneficiary communities can obtain them by offering socioeconomic rehabilitation assistance acceptable to the affected persons.  Private Land on “Voluntary Contribution�: The concerned landowners, if persuaded, may elect to contribute the lands without compensation.  Private Land on “Contribution Against Compensation�: Where the concerned landowners are marginal and voluntary contributions are infeasible, the beneficiary communities can offer this option as an incentive for contribution. 77. Private landowners will have the option to refuse voluntary contribution and accept the “contribution against compensation� offer without the fear of any adverse consequences. 78. Tribal Peoples Strategy: Impacts on tribal peoples will vary in terms of adaptation measures, the size of tribal population in the area, and social risks. The SMF aims to ensure that proposed activities do not adversely affect TPs, and that they are culturally compatible and do not threaten their traditional way of life. Depending on their presence in the sub-project area and their needs and concerns, NGOs will prepare their proposals with the following strategic objectives:  Select adaptation measures and determine their scope to avoid or minimize, to the extent feasible, adverse impacts on TPs;  Where adverse impacts on TPs are unavoidable, adopt and implement socially and culturally appropriate measures to mitigate them. 47  Wherever possible, adopt measures—in addition to those for impact mitigation—to reinforce and promote any available opportunities for socioeconomic development of the TP communities;  Ensure that TP communities in general and their organizations, if any, are fully included in the process leading to selection, design and implementation of the adaptation measures;  Together with TPs, screen the adaptation measures for a preliminary understanding of the nature and magnitude of potential impacts and, if necessary, explore alternatives to avoid or minimize adverse impacts.  Where alternatives are not feasible and adverse impacts are unavoidable, NGOs/PKSF, together with TPs and others knowledgeable of tribal culture and concerns, will make an assessment of the key impact issues. 79. NGOs/PKSF will undertake the tasks necessary to adopt appropriate mitigation measures. The most important in this respect is intensive consultation with the TP communities, community elders/leaders, and formal and informal TP organizations, civil society organizations such as NGOs, and others who are interested in and have knowledge of TP issues. 80. Social and Gender Issues: While preparing sub-project proposals, NGOs will undertake an assessment of the target communities to gather views and preferences of the different stakeholder groups, including women, in order to improve sub-project design and establish a participatory process for implementation and monitoring. Social and gender issues will be given due attention during identification, design, implementation, and monitoring. Baseline information on key social and gender issues prevailing in the communities will be disaggregated by gender and analyzed in the identification stage, and any issues will be integrated into measurable indicators. Capacity development exercises for integrating social and gender issues will be carried out, and data on indicators will be collected during implementation and monitoring. Outcomes and impacts of social and gender issues will be assessed at sub-project completion. 81. Stakeholder Consultations: Extensive consultations with the community and other stakeholders and persons knowledgeable on climate change issues will be key to undertaking community-based climate change adaptation measures and integrating social and gender issues into sub-project proposals. In addition to open community meetings, the NGOs will hold separate consultations/focused group discussions with women, tribal peoples, and other vulnerable groups to achieve a better understanding of how they have been impacted by climate change, and what measures would help them most to cope with or adapt to its impacts. 82. As required for informed consultations with TPs, PKSF/NGOs will provide TP communities with all information related to the probable adaptation measures, including potential adverse impacts. To facilitate consultations, PKSF/NGOs will:  Prepare a timetable for TP consultations leading to selection, design and implementation of the adaptation measures, and consult TPs in a manner that allows them to express their views and preferences freely. 48  In addition to the communities in general, consult TP organizations, community elders/leaders, and others to ensure adequate gender and generational representation; as well as civil society organizations and groups knowledgeable of TP issues. 83. In addition to the choice of alternative adaptation measures, consultations will concentrate on the adverse impacts, if any, perceived by the TPs and the probable (and feasible) mitigation measures; and explore additional development activities that could be promoted under the sub-project. 84. Institutional Arrangement and Capacity Building: The PMU will hire a program officer with background in training and community/social development (PO-TCSD) to assist the project coordinator in managing overall implementation of SMF, including compliance with the social safeguard requirements. The PMU will provide technical guidance to the PC to shortlist and appraise sub-project proposals and, on a demand basis, to assist the NGOs whose proposals are accepted for financing. The PC will form an evaluation team comprising members from the PMU and the technical reviewers whenever the team needs expert opinions on the proposals. The PMU will engage the necessary number of POs to supervision and monitor sub-project activities in each of the three vulnerable zones. The POs will liaise with the implementing NGOs and monitor implementation of the individual sub-projects, including those that involve social safeguard issues. The PO-TCSD at PMU will guide and assist the zonal POs in SMF implementation monitoring and ensuring compliance with SMF guidelines. The PMU staff will receive advance training on climate change adaptation, including social safeguards compliance. PKSF will also consider local and foreign training and technical backup support from specialized organizations, if required, to continuously improve the capacity of the staff members dealing with activities under CCCP. 85. Grievance Redress Mechanism (GRM): A GRM will be established at the central (PKSF) and sub-project levels to deal with any complaints/grievances about environmental and social issues. At the sub-project level, the union parishad (UP) chairman or his/her nominated representative from the UP will be the local grievance redress (GR) focal person for addressing the grievances. The concerned PO or any other official nominated by the PC at the PMU will be the GR focal person at PKSF. The aggrieved person or entity will submit the complaint/grievance in a sealed envelope to the UP focal person, who will deliver it to the implementing NGO and ensure that it is entered in the Grievance Register, and collect a receipt. The implementing NGO will not open the envelope, but inform the local GR focal person about receipt of complaint and schedule hearings as per his/her advice. In an open meeting, he/she will hear and discuss the complaint and attempt to resolve it in view of the applicable guidelines of the SMF. The aggrieved person, if female, will be assisted by a female UP member in the hearing, and if from a tribal community, by a tribal representative. It is expected that all complaints at the sub-project level will be addressed within 15 days, failing which the petitioner can seek resolution from the focal person at the PKSF headquarters. The NGO will forward any unresolved cases with the proceedings to the PC at PKSF headquarters within 7 days of hearing by the local GR focal person. 86. An aggrieved person can send a complaint directly to the managing director (MD) of PKSF at any time. The MD will review and resolve the complaint at his/her discretion. The 49 MD may seek advices from the PKSF Chairman on any critical issues, at his/her discretion. The aggrieved person or entity will have the option of lodging the complaint directly with the Governing Council at BCCRF Secretariat if not satisfied with resolutions up to the MD level. A decision agreed by the complainants at any level of hearing will be binding on the concerned NGOs and PKSF. The GRM will, however, not pre-empt an aggrieved person’s right to seek redress in the courts of law. The institutional arrangements for the Grievance Redress Mechanism are shown in the figure below. Institutional Arrangement of the GRM Aggrieved Persons/Entities Local GR Focal Person GR Focal Person at PKSF Project Coordinator, PKSF Managing Director PKSF Chairman PKSF Governing Council BCCRF Secretariat 87. The aggrieved person/entity will also have the option to lodge the complaint directly with the PC (GR focal point at PKSF) if it is against the NGO; to the PKSF MD if it is against the PKSF project management; and to the Governing Council at BCCRF Secretariat if there are any issues related to PKSF itself. 88. The provision of GRM and the process will be well disclosed to the community and the likely affected persons before implementation of the sub-projects. The disclosure will be done by the NGOs and overseen by the POs. NGOs/PKSF will keep the records of all resolved and unresolved complaints and grievances and make them available for review as and when requested by the World Bank. The case records will also be posted on the CCCP website. 50 89. Social safeguard compliance monitoring will be done by the existing M&E unit in PKSF, where an M&E specialist dedicated to CCCP will be engaged at the PMU to look monitor all activities. The POs will undertake quarterly monitoring visits to validate the monitoring already undertaken by the NGOs with community participation. The M&E specialist will provide necessary technical guidance to POs on monitoring social safeguard compliance requirements. The social safeguards compliance issues, along with other activities, will be reviewed at mid-term and evaluated at completion of the sub-project. PKSF and the Bank will conduct a mid-term and end-term evaluation for the CCCP overall. Social Risks and Issues Beyond Coverage of the Safeguard Policies 90. No social risks or issues are anticipated that fall outside the coverage of the safeguards policies. Non-safeguard social and gender issues will be attended to in accordance with the guidance notes on social inclusion contained in the SMF. Monitoring and Evaluation Scope and Function 91. The project will be monitored in two levels – the performace of PKSF in the establishment and implementation of the sub-grant financing mechanism, and the performance of NGOs in the implementation of the sub-grants. PKSF will be responsible for setting-up a functioning Project Management Unit (PMU), the sub-grant mechanism, and ensuring effective implementation of the fiduciary aspects throughout the project including environmental management, social assessment and management, financial management, and procurement management. A third party monitoring will be conducted as frequently as necessary, to assess the effectiveness of PKSF as the implementing agency and monitor the sub-projects implemented by NGOs for adressing the climate risk for each of the selected regions. An annual Third Party monitoring and Third Party impact evaluation at mid-term and project completion will be conducted to determine the progress towards the achievement of the project development objectives. 92. Each sub-project will be subject to monitoring by both the implementing NGO and PKSF. However, the frequency and subject of monitoring, depending on the monitoring framework detailed in the sub-project proposal. A detailed M&E manual consistent with PKSF’s overall results-based monitoring system and CCCP results framework will guide the monitoring practices of PKSF and the implementing NGOs. 93. The monitoring under CCCP will have three functions. First, it will allow CCCP to ensure that the NGOs deliver the outputs agreed in their sub-project proposals, indicating that the resources are used efficiently for the proposed activities. Second, monitoring will establish proper documentation of the implementation process and achievements at different levels (outputs, outcomes and impacts). Third, monitoring will help capture learning from the process. Since adaptation experience is highly contextual, documentation of learning under different context will add to the knowledge base for future actions. In short, the role of accountability is 51 significant in case of outputs, whereas learning becomes a core issue of monitoring at the level of outcomes and impacts. Monitoring Process 94. Tasks and Duties of Monitoring Officer at NGO: The implementing NGO will employ a dedicated monitoring officer (MO), who will report to the Chief Executive or senior official not directly entrusted with the implementation of the program. S/he will implement the monitoring framework as envisaged in the sub-project proposal and will produce quarterly activity monitoring reports based on the agreed-upon Activity to Output Monitoring (ATOM) framework. The MO will undertake outcome-level monitoring half-yearly based on the agreed Outcome Assessment Sheet (OAS), and impact-level monitoring annually based on the agreed Impact Assessment Sheet (IAS), which will be prepared taking indicators of impacts and outcomes into account. S/he will enter the information in the PKSF server as well. Monitoring Framework 95. Each sub-project will include a monitoring framework as follows: Results Indicators Info needed Methods Respondents Frequency Impacts Outcomes Outputs 96. The implementing NGO will use the monitoring framework to identify the information needed against indicators at the level of impacts, outcomes and output. It will select the respondents and the information data collection methods. The MO will collect information at the output level quarterly, and at the outcomes and impacts level half yearly and yearly. 97. The information thus collected will be inserted in a table as follows: Results Indicators Achievement Variations Reasoning Recommendations/ plan modifications Impacts Based on IAS Outcomes Based on OAS Outputs Based on NGO implementing staff 98. The MO will enter the data received from monitoring visits and office records in the specified table of the server of the PKSF, which will auto-generate the monitoring report. The MO will submit the report along with recommendations for possible variations in the planned activities agreed upon with fellow staff members of the implementing NGO. 99. Activity Monitoring: The implementing NGOs will employ a dedicated monitoring officer who will report to the Chief Executive or senior official. The information thus collected will be entered in an activity monitoring chart: 52 Activity Monitoring Chart Activities Indicators Achievement Variations Reasoning Actions for next reporting period 100. The MO will enter the data received from monitoring visits and office records in the specified table of the PKSF server, which will auto-generate the monitoring report. The MO will submit the report along with recommendations for possible variations in the planned activities agreed upon with fellow staff members of the implementing NGO. 101. Participatory Monitoring: The Monitoring Officer will be responsible for ensuring that community members, including local elected representatives, teachers and other socially regarded persons participate in the regular monitoring exercises. The MO will use the information provided by the community representatives to complete the monitoring framework shown above. The implementing NGO will seek participation of the community in its recurrent monitoring at different levels of results, and will include the monitoring information from the community separately in the monitoring report to be sent to PKSF. 53 PKSF Level 102. Task and Duties of the Program Officer: Based on the monitoring information available to PKSF, the relevant PO will seek clarifications or explanations or learning from any deviations. The PO will undertake monitoring visits quarterly and validate the monitoring already undertaken by the implementing NGOs. Each PO will prepare his/her own monitoring report half yearly and make recommendations on the next disbursement. 103. Task and Duties of Audit Officer: Each implementing NGO’s finance, accounting and procurement practices will be subject to internal audit every six months by the audit officer (AO), who will provide an opinion on whether the next disbursement is justified. 104. Task and Duties of Senior Accounts and Finance Officer: The PO and AO will send their recommendations to the Finance Officer (FO). If there is no objection on their part, s/he will prepare for the next disbursement to be signed by the PC. If PO or AO does not recommend the next disbursement, the FO will ask the contact person at the implementing NGO to resolve any issues with the PC. 105. Tasks of Central M&E Unit of PKSF: The M&E unit of PKSF will undertake quality control of the monitoring activities of the POs and provide capacity building wherever necessary. It may also organize training on monitoring for staff of the implementing NGOs. The M&E unit will also assist the POs to summarize the NGO’s monitoring reports under different pillars/themes, and prepare half-yearly progress reports and annual reports for review by the PC. 106. External Evaluation of Sub-projects: PKSF will engage an external evaluator to assess the impacts of the sub-projects. In case the sub-project is three years or more, a mid-term external evaluation will be undertaken. The evaluation team will comprise one member of the PMU and technical reviewers who have not been involved in the appraisal of the sub-project. The evaluation team will be headed by the external member of the team. 107. External Evaluation of CCCP CCCP will be subject to external impact assessment, a mid-term evaluation and a final evaluation. PKSF and the World Bank will jointly formulate the terms of reference. 54 Annex 4: Operational Risk Assessment Framework (ORAF) Bangladesh: Community Climate Change Project Stage: RVP Approval 55 Project Stakeholder Risks Rating: High Description : Reputational risk associated with Risk Management: Selection criteria will be widely publicized, and the process unsuccessful NGO proposals and corresponding will build in measures of transparency and accountability to ensure that the process tension. remains fair. A third party monitoring unit will be contracted by the PKSF to undertake impact monitoring of the sub-grants and derive the lessons learnt. Stage: Status: Not yet Resp: PKSF Due Date : Ongoing Implementation due Resp: Stage: Due Date : Status: Implementing Agency Risks (including fiduciary) Description : PKSF is a microfinance organization, Risk Management : and may lack the specific technical and management PKSF will establish a PMU for project implementation. The project will establish experience to execute and supervise the program objective assessment criteria to screen and select NGOs. An Evaluation Team . consisting of appropriate Technical Experts will screen and evaluate each NGO proposal prior to their being approved for funding. Implementation of the project will also be done by suitable technical staff as the NGO level and will be supervised by technical experts from the PMU Status: Not yet Resp: PKSF Stage: Prep Due Date : due Governance Rating: Moderate Description: The number of proposals expected Risk Management: PKSF has a governance structure in place with a Governing could provide a challenge to PKSF to maintain Body of directors that is well established. The review of proposals to fund will be oversight, accountability and transparency in the done by Evaluation Teams of specialists hired by PKSF. The PMU will be selection process. provided with sufficient resources to hire the necessary staff to maintain oversight with transparency. Publishing proposals publically on the internet or through other sources to improve transparency and accountability in the selection process 56 Stage: Status: Not yet Resp: PKSF Due Date : Implementation due Project Risks Design Rating: Substantial Description : Risk Management : Climate change adaptation is a new field for both A PMU with multi-disciplinary expertise will be established in PKSF to PKSF and many NGOs, with little expertise or specifically oversee the implementation of the CCCP project. In addition, an capacity to have a maximum impact on the ground. extensive communication package will be developed along with workshops to raise the awareness of NGOs preparing adaptation proposals. PMU will also provide assistance to NGOs at both proposal preparation phases as well as during implementation, as necessary. Finally, a comprehensive monitoring and feedback mechanism will be designed to ensure that the program learns from experience Resp: PKSF & Status: Not yet Stage: Preparation Due Date : Bank due Social & Environmental Rating: Substantial Environment Risk Management :  Uncertainty in identifying specific type of Environment: An Environment Management Framework (EMF) and sub-grant activity Environmental Management Plans for each sub-project has been prepared and disclosed. The Project Management Unit (PMU) will have a full time focal person with Environmental Specialization or a full time Environment and Natural  Weak capacity to ensure environmental Resource Management Specialist. PKSF will develop its own monitoring plan to safeguard and implement environmental oversee environmentally critical sub-project. S/he will be responsible for ensuring environmental safeguard compliance at concept, proposal, implementation and management plans. operation and monitoring stage. Apart from the Environmental Focal person of PKSF NGOs will nominate an environmental specialist who will be responsible Risk Explanation: for environmental screening, Initial Environmental Examination if necessary, The innovative nature of the project, uncertainty and developing sub-grant activity specific mitigation measure and Environmental location specific climate change interventions pose Management Plan and quarterly monitoring report. significant risk for both the PKSF and the NGOs to adopt effective environmental and social safeguards. Social: Although the social safeguards compliance issues would remain unknown until an SGP is actually received and reviewed, PKSF has prepared a Social 57 The risk further compounded by inadequate PKSF Management Framework (SMF) for CCCP following the OP 4.12 on Involuntary and NGO capacity to ensure environmental safeguard Resettlement and OP 4.10 on Indigenous Peoples. The SMF provides the compliance in the sub-grant activity. principles and guidelines to address social safeguards compliance issues that may Social: The project desires that sub-grant proposals arise during implementation of the sub-projects including gender and other social (SGP) will avoid social safeguards impacts those concerns. The SMF will be followed to screen SGPs for social safeguard cannot be mitigated within the existing capacity of compliance, monitor implementation and carry out impact evaluation of the sub- the community, the NGOs or PKSF. It is also desired projects. Project management office at PKSF will have a community/social the sub-projects will not reduce climate change development specialist for implementation of the SMF to ensure social safeguards vulnerability to one gender or community group at compliance. the cost of others including tribal peoples. The sub- project may also be undertaken in areas with small concentration of tribal peoples triggering OP 4.10 on indigenous peoples. The project policy is adopted to avoid acquisition of private land (using power of eminent domain) and in special circumstances, private lands and public lands with private uses will Resp: PKSF will be used through voluntary contribution and/or Stage: Due Date : Status: Not yet ensure and the Bank contribution against compensation collectively by the Implementation 12/31/2016 due oversight community, failure in which, NGOs will select to purchase the lands directly. There is a risk that appropriate mitigation measures are not applied during identification, design and implementation of the sub-projects. Program & Donor Rating: Substantial Description: The project is being funded through a Risk Management: Close partnership and communication during project multi-donor trust fund, which will require continuous preparation and implementation with donor partners and BCCRF to solidify investments over the long term to have any commitment for a longer-term. Documenting lessons learned for continuous significant impact. Furthermore, the creation and improvement and the dissemination and communication of results to demonstrate strengthening of institutions is a long-term process. impacts on the ground. There is a risk that the donors do not continue funding the BCCRF. Resp: Bank Stage: Ongoing Due Date : Ongoing Status: 58 Delivery Monitoring & Sustainability Rating: Substantial Description: This project will be a challenge to PKSF Risk Management: A dedicated Project Management Unit with Operational because PKSF is a micro-credit organization and it is manual and M&E manual will be established to ensure the implementation of the PKSF’s first time implementing a grant mechanism, program. Provision has been made to recruit external advisers as necessary on and a program in climate change sector and specific climate change issues that may arise. The systematic documentation of the monitoring the impact of such programs. impact of the program and communication to BCCRF will be undertaken to ensure continued funding from BCCRF. The Ministry of Environment and Forests has also designated PKSF as the implementing agency for NGO component of the Government Climate Change Trust Fund. Resp: Bank & Stage: Ongoing Due Date : Ongoing Status: PKSF Resp: Stage: Due Date : Status: Overall Risk Following Review Preparation Risk Rating: 7.2 Implementation Risk Rating: Substantial Comments: Comment: Note : Include on average no more than 3 Risk Management Measures per Risk Category. 59 Annex 5: Implementation Support Plan BANGLADESH: Community Climate Change Project Strategy and Approach for Implementation Support 1. The Implementation Support Plan takes into account the relatively simple design of the project, its corresponding risk profile, and the country counterpart’s institutional capacity. It focuses on the risk mitigation measures identified in the ORAF. In parallel, it strives to provide the client with flexible and effective assistance through the duration of the project, while helping build essential institutional capacity and creating an enabling environment for the development and implementation of community-based adaptation sub-projects. 2. Procurement: Implementation support will include (a) provision of customized training on procurement of goods and services to the PMU; (b) clearance of procurement plans and review (prior and post) of procurement actions; (c) review and assistance to PKSF to develop the sample sub-grant agreement between PKSF and grant beneficiaries; (d) contribution to a long- term capacity building plan for PKSF to enable it to handle larger projects; and (e) review of procurement performance improvement plan (PPIP) as part of procurement risk mitigation. 3. Financial Management: Implementation support will include: (a) helping client with the format for establishing IUFR-based disbursement; (b) supervision reviews of the project’s financial management system to ensure the quality of financial management, internal control, and internal audit for the project; and (c) review of the external and internal audit reports for the project. 4. Social Safeguards: Implementation support will include (a) guidance on any issues arising from implementation of agreed-upon SMF; (b) specialized training for PMU and NGO staff on social safeguard policies of the Bank and SMF; (c) assisting PKSF/NGOs in incorporating social information into a database for project and sub-project monitoring; (d) review of required social screening for identification, selection and implementation of sub- projects; and (e) review of social management actions during implementation, monitoring and evaluation. 5. Environmental Safeguards: Implementation support will include (a) guidance on any issues arising from implementation of agreed-upon EMF, (b) specialized assistance for PMU/NGO staff on environmental safeguard policies of the Bank and EMF; (d) review of the technical committee’s assessment of required environmental screening for identification, selection and implementation of sub-projects; and (e) review of environmental management actions during implementation, monitoring and evaluation. 6. Institutional Capacity Building and Technical Inputs: The project provides for institutional development and technical strengthening of PKSF to administer a grant financing mechanism for community-based climate change adaptation sub-projects. It also provides institutional support to NGOs to design, implement and monitor such projects. Implementation 60 support will include (a) strategic advice on grant financing programs, including transparency and accountability in providing sub-grants; (b) technical guidance to PKSF on climate change issues; (c) policy and technical advice on adaptation options and program design; and (d) promotion of community ownership and buy-in for the sub-projects. Implementation Support Plan 7. The project will be supported on a routine basis by the core task team based in the World Bank’s Dhaka country office, including the project’s TTL and specialists in procurement, financial management, environment and social safeguards. Additional specialized technical expertise will be available from headquarters and regionally on as-needed basis. Formal supervision and field visits will be conducted semi-annually. Detailed inputs will be as follows:  Fiduciary inputs: Initial training will be provided to FM staff on the financial management and disbursement-related arrangements agreed with the Bank. Supervision will be done on the IUFR on a quarterly basis, overall financial management progress and arrangement will be reviewed during the missions, and annual review will be done on the external and internal audit reports. Training will be provided to staff of PMU and PKSF on procurement procedures and regular review of procurement monitoring reports.  Social safeguards: Given its limited capacity and knowledge on social safeguard compliance in project design and implementation, PKSF will need continued support from the social development specialist on the core team. In sub-projects with land-based physical works, the safeguards support will be extensive, from identification through implementation, monitoring and evaluation. The PMU staff and selected NGOs, at each call for proposals, will be provided with local training on implementation of the SMF. Field visits will be carried out on a semi-annual basis and as required in the first year.  Environmental safeguards: PKSF has no experienced person to deal with environmental safeguard issues, as required by the EMF. In addition, since the implementing NGOs are yet to be identified, their capacity to implement safeguard policies cannot be determined at this stage. Additionally, the innovative nature of the project and location-specific interventions pose significant risks for both the PKSF and the NGOs being able to adopt effective environmental safeguards. PKSF will need continued support from the environmental specialist on the core team to develop its capacity and implement the EMF. The PMU staff and selected NGOs, at each call for proposals, will be provided with local training on implementation of the EMF. Field visits will be carried out on a semi-annual basis and as required.  Operational and technical inputs: A field-based TTL will provide day-to-day oversight and coordination with the client, development partners, and team members. The team’s technical specialists will conduct annual site visits timed in line with the project deployment schedule, with an option for semi-annual supervision. 61 Table A: Estimated Implementation Support Plan Time Focus Skills Needed Resource Partner Role Estimate First twelve Procurement training and Procurement 4 SW Assign trainees & months Procurement review Specialist focal persons FM training and FM Specialist 4 SW Assign trainees & supervision focal persons Environmental Environment 4 SW Assign trainees and management training Specialist focal persons Social management Social 4 SW NA training Development specialist Project planning, Adaptation 4 SW implementation, and M&E specialist Saline, flood, & drought Water 4 SW region project design engineer/civil engineer Team leadership, TTL 10 SW institutional arrangements, and project supervision 12-48 months Procurement post review Procurement 12 SW Specialist Financial management FM Specialist 12 SW supervision Environmental monitoring Environment 16 SW and reporting review Specialist Social management Social 16 SW NA monitoring & training Development specialist Project planning, Adaptation 16 SW implementation, and M&E specialist Saline, flood, & drought Water 16 SW region project design engineer/civil engineer Team leadership, TTL 40 SW institutional arrangements, and project supervision 62 Table B: Summary of Skills Mix Requirements Skills Needed Number of Staff Weeks/Budget Number of Trips Comments Procurement 16 Once annually Region-based Financial management 16 Two annually Region-based Environment 20 3 in first year and then Region-based two annually Social 20 3 in first year and then Region-based semi-annually Adaptation specialist 20 As required Region-based Water/civil engineers 20 As required Region-based TTL 50 2 annually Region-based 63