The World Bank RESTRUCTURING ISDS Romania Integrated Nutrient Pollution Control Project (P093775) Integrated Safeguards Data Sheet Restructuring Stage Restructuring Stage | Date ISDS Prepared/Updated: 08-Apr-2019| Report No: ISDSR26930 Regional Vice President: Cyril E Muller Country Director: Arup Banerji Regional Director: Steven N. Schonberger Practice Manager/Manager: Kseniya Lvovsky Task Team Leader: Cesar Niculescu The World Bank RESTRUCTURING ISDS Romania Integrated Nutrient Pollution Control Project (P093775) . I. BASIC INFORMATION 1. BASIC PROJECT DATA Project ID Project Name Romania Integrated Nutrient Pollution Control Project Task Team Leader(s) Country Cesar Niculescu Romania Approval Date Environmental Category 30-Oct-2007 Partial Assessment (B) Managing Unit Is this a Repeater project? SCAEN PROJECT FINANCING DATA (US$, Millions) SUMMARY -NewFin1 Total Project Cost 127.62 Total Financing 127.62 Financing Gap 0.00 DETAILS -NewFinEnh1 World Bank Group Financing International Bank for Reconstruction and Development (IBRD) 121.69 International Development Association (IDA) 5.93 IDA Credit 5.93 Non-World Bank Group Financing Trust Funds 5.50 Global Environment Facility (GEF) 5.50 The World Bank RESTRUCTURING ISDS Romania Integrated Nutrient Pollution Control Project (P093775) 2. PROJECT INFORMATION Current Project Development Objective The development objective of the project is to support the Government of Romania towards meeting EU Nitrate Directive requirements at a national scale. . 3. PROJECT DESCRIPTION The Additional Financing (AF) for INPCP would finance the costs associated with the scale-up of the initial project Integrated Nutrient Pollution Control Project (INPCP) (P093775) nationwide, based on complementarity (to investments and planned activities by the GoR, EC funds availability, other donor’s involvement) and demand-driven principles (communes selected based on competitive application process), incorporating lessons learned thus far. It expands the coverage to the entire country and takes into consideration the location specific requirements of its different farming systems and agro-ecological regions. The AF is financing works, goods, services and operating costs and comprises four components, which are largely the same as in the INPCP with slight modifications: Component 1: Investments in Local Communities to Reduce Nutrient Pollution: This component will provide support for effective investments and management practices to reduce nutrient pollution from agricultural, livestock and human sources. This component builds upon the experiences and lessons learnt from the on-going INPCP and includes support for a menu of investments focusing on manure collection and composting facilities, manure management biogas production from animal waste and adoption of code of good agricultural practices in about 100 communes highly exposed to nitrate pollution in all 11 river basins in Romania, covering all the 8 development regions. The financial support provided within the Additional Financing will be demand-driven, supported on competitive grounds, based on the beneficiary communities’ requests and eligibility. The communes will propose sub-projects, selected from a menu of investments based on agreed eligibility criteria and having the main objective to reduce water pollution with nutrients. The selection and approval of sub-projects will be done on a competitive basis, for eligible activities and applicants. A detailed Applicants’ Guidelines for the Competitive Investment Program will be also developed to prov ide guiding principles and rules for its implementation at the local, regional and national levels, describing in detail the eligibility criteria, selection and award procedure. Under this component the Project will support investments and management practices to reduce nutrient pollution from agricultural, livestock and human sources, such as: 1.1 Developing local community storage, composting and handling systems, packing/pelleting stations and biogas facilities, all to promote better management of livestock and household waste; 1.2 Planting of vegetative buffer strips, including tree planting and afforestation; 1.3 Sewage and wastewater treatment activities; and 1.4 Provision of equipment to upgrade the existing manure storage and/or composting facilities; The World Bank RESTRUCTURING ISDS Romania Integrated Nutrient Pollution Control Project (P093775) A menu of customized eligible investments for nutrient pollution reduction will be available, including facilities for anaerobic digestion as co-generation installations/biogas stations using the animal waste as main source of energy. Component 2: Institutional Strengthening and Capacity Building: The Project will support activities that aim to strengthen institutional capacity and coordination within relevant national and local governments, institutions, agencies and stakeholders for regulating, implementing, monitoring and reporting the EU Nitrate Directive requirements. The project will contribute to building capacity by providing equipment, other required facilities and specialized training for MWF, ANAR, MARD, Agriculture Payments and Intervention Agencies (APIA), National and Local Environment Protection Agencies, Environmental Guard, Public Health Directorates, and selected Research Stations and County Offices for Soils and Agro-Chemistry. The financial support will include: 1. Developing knowledge and training activities (through providers) and supporting on-farm demonstrations to improve the adoption and compliance by farmers of the Code of Good Agricultural Practices. 2. Providing support to: (a) ANAR to monitor and report to the MWF and EU on the quality of surfacewater and groundwater under the EU Nitrates Directive and the EU Water Framework Directive, through: (i) the acquisition of equipment for groundwater wells; (ii) the construction of groundwater wells; (iii) the acquisition of laboratory equipment and related software; and (iv) the provision of technical assistance for, inter alia, the carrying out of studies and the development of software; (b) Institutions represented in the Inter-Ministerial Committee for Application of the EU Nitrates Directive (ICA). 3. Carrying out of a comprehensive training program for the staff of the relevant national, regional and county level agencies on monitoring, control and reporting under the EU Nitrates Directive and EU Water Framework Directive. 4. Improving the capacity building system able to support the scaling up, at the national level, of the implementation process of the EU Nitrate Directive and Water Framework Directive. 5. Providing technical assistance to: (i) update the Code of Good Agricultural Practices and revise action programs; and (ii) carry out activities to promote the adoption by the farmers of the improved nutrient management practices set forth in the Code of Good Agricultural Practices. 6. Support for the development of eight knowledge and training hubs (one in each development region) to promote adoption of good agricultural practices to reduce on farm nutrient pollution. Component 3: Public Awareness and Information Support: The continuity of the awareness campaign and its replication in other areas of the country is necessary. None of the activities proposed are new or different in their nature from those currently being implemented under INPCP. In addition to information provision under the public awareness campaign, the AF will provide some channels for direct citizen engagement (e.g., PMU contact information, Facebook, twitter). The opportunities for providing feedback, the analysis of such feedback and the report back to communities on its results, will be strengthened under the Additional Financing. The public awareness campaign and associated activities will reflect the needs and interests of different groups, such as Roma communities and gender groups. The surveys on knowledge, attitudes and behavior will be expanded to allow for qualitative data collection and the consolidated results of the surveys will be shared with participating communities in a user-friendly format. Participating municipalities will be requested to provide summaries of public consultation, including the feedback received and the responses provided. One objective of this component will be to promote the financial instruments that will be available within the AF to potential beneficiaries. The World Bank RESTRUCTURING ISDS Romania Integrated Nutrient Pollution Control Project (P093775) This objective will be reached through face-to-face meetings, where the beneficiaries will find out about the Calls for Proposals sessions and will b taught how to prepare their proposals in order to be eligible. Component 4: Project Management: This component will provide supporting the PMU in connection with Project implementation, monitoring, reporting, evaluation and impact assessment through the provision of: (i) funds for Incremental Operating Costs and for the acquisition of goods; (ii) non-consultant services and consultants' services including, inter alia, audit and social surveys; and (iii) training. The Additional Financing Project will be implemented by the existing PMU located within the MWF, enhanced with specialists in evaluation and selection of sub-projects proposals. While the beneficiaries will have a more active role in the sub-projects proposals and implementations, the PMU will have an extended role in providing information regarding the project and monitoring all project’s activities, as well as ensuring the coordination of all in terventions aimed at implementing the Nitrates Directive. This will involve a revision of the PMU procedures for clarifying the coordination mechanism between PMU, the beneficiaries and other institutions involved in the implementation of the Nitrates Directive. The Applicant’s Guidelines, as part of the Project Operational Manual, will detail the role and competencies of the PMU in the process of evaluation and selection of the sub-projects proposals under the first component. The PMU’s role in the implementation of the other three components of the project will remain unchanged. Most of this AF – about €35 million – is foreseen to continue the financing of small investments (manure storage and collection concrete-made platforms at the commune level) in rural communities, bringing at the same time important environmental and social-economic benefits. SAFEGUARDS PERFORMANCE INPCP-Additional Financing safeguards performance is satisfactory, and the PMU’s capacity in managing environmental and social safeguards is sound. All small-scale investments/civil works (manure management reinforced concrete-made platforms at the commune level and some composting facilities) are implemented in compliance with the World Bank environmental safeguards, with health & safety requirements for such type of construction activities, and with proven environmental safety. The PMU and the Bank’s environmental consultant developed ESMP review checklists that are applied to evaluate the quality and completeness of the site-specific ESMP prepared by local beneficiaries. There was no significant impact to environment and no social related aspect registered so far during the works execution, or during the operation phase of executed investments under INPCP. RATIONALE FOR RESTRUCTURING After the deadline for the submission of Full Applications included in the domain of intervention D1 (“ Developing local community storage, composting and handling systems, packing/ pelleting stations and biogas facilities, all to promote better management of livestock and household waste�) and following a detailed analysis of received applications, a total number of 89 proposed investments were selected at the end of 2018 for financing under Component 1 of INPCP. The AF project is being restructured due to the need to trigger OP 4.04 – Natural Habitats which was not triggered at the time of appraisal. At appraisal, it was assessed that all investments and other project interventions would occur on public land within the beneficiary communes’ perimeter, and with no indication that it might be located next or within protected areas and/or natural habitats. However, following a new safeguards analysis and considering the environmental conditions and specific measures included in the permits issued by the local environmental protection authorities for each new investment (platforms for animal waste management) selected to be financed under the project, it was concluded that 9 out of 89 new investments have the proposed location in protected areas (Natura 2000 sites) established in Romania, and hence OP 4.04 requires to be triggered. . The World Bank RESTRUCTURING ISDS Romania Integrated Nutrient Pollution Control Project (P093775) 4. PROJECT LOCATION AND SALIENT PHYSICAL CHARACTERISTICS RELEVANT TO THE SAFEGUARD ANALYSIS (IF KNOWN) The proposed AF will scale-up the original project nationwide, and would allow for six more years the financing of investments in local communities for reducing nutrient pollution, as well as support institutional strengthening and capacity building for compliance and improved agricultural practices. A menu of investments focusing on communal storage and handling systems to promote better management of livestock and household waste, composting and packing/pelleting facilities, buffer strips, pastures rehabilitation and afforestation to improve the protection of water bodies and adoption of code of good agricultural practices in additional 100 communes highly vulnerable to nitrate pollution in all 11 river basins in Romania. In addition, the AF project will continue to demonstrate the impact of small-scale sanitation facilities on nutrient load reductions by supporting the construction of small sewage networks and compact wastewater treatment plants for about three-four communities that already implemented measures to mitigate the pollution with nutrients originating from agriculture, but where this is still imminent due to the households having non-septic tanks from which effluent leaks directly into the groundwater. 5. ENVIRONMENTAL AND SOCIAL SAFEGUARDS SPECIALISTS ON THE TEAM Dariusz Kobus, Environmental Specialist Mohamed Ghani Razaak, Social Specialist Valerie Morrica, Social Specialist SAFEGUARD_TABLE 6. SAFEGUARD POLICIES TRIGGERED Safeguard Policies Triggered Explanation The required mitigation measures for the AF project activities are standard and widely used in construction practices. They were already well prescribed in the Environmental Management Plan (EMP) which was prepared for the original project. Whereas the AF project will support the same types of activities as under the original project, the exiting EMP was updated, approved and disclosed in December 2015, and further applied also for this Environmental Assessment (OP) (BP 4.01) Yes new project. As concluded by the environmental assessment carried out for the INPCP – AF preparation, the project is categorized as environmental Category B, and triggers only two safeguards policies: OP 4.01 – Environmental Assessment, and OP 7.50 – Projects on International Waterways. Moreover, at the time of appraisal, there was no indication to suggest that the Natural Habitats policy would be triggered for The World Bank RESTRUCTURING ISDS Romania Integrated Nutrient Pollution Control Project (P093775) the investments envisioned under the project in this second phase of implementation. However, following a new safeguards analysis and considering the environmental conditions and specific measures included in the permits issued by the local environmental protection authorities for each new investment (platforms for animal waste management) selected to be financed under the AF project, it was concluded that 9 out of 89 new investments have the proposed location in protected areas (Natura 2000 sites) established in Romania, and hence OP 4.04 has to be triggered. The project’s EMP approved and disclosed in December 2015 was updated adequately as to include the specific conditions and requirements related to the protection of natural habitats and Natura 2000 sites as requested by the national legislation and by the Bank safeguard policy – OP 4.04 Natural Habitats; this revised document was re-disclosed locally and on the Bank’s website. The EMP stipulates that all contracts for construction works will include requirements for implementation of the specific measures as per EMP provisions, including protected areas and good construction practices. In addition to the overall project EMP which identifies the range of issues expected, all sub- investments will require an environmental approval (agreement) from the local environmental protection agency. The Project is expected to have limited negative environmental and social impacts, as physical works will be undertaken to only construct local, small-scale facilities. The potential environmental risks generated by the construction and operation of a few investments (manure management platforms) proposed for being located within Natura 2000 sites relate to the protection of bird species (disturbance to breeding birds which may result in a decrease of the populations over time due to construction noise and human presence) and, in one location, to the protection of butterflies (attraction of common/invasive insects or other butterflies by the presence of manure/compost). The long-term environmental impacts anticipated are positive and linked to the overall project The World Bank RESTRUCTURING ISDS Romania Integrated Nutrient Pollution Control Project (P093775) development objective to reduce nutrients in surface and ground water bodies. Performance Standards for Private Sector No Activities OP/BP 4.03 At appraisal, it was considered there would be no activities associated with the project that would take place within or in the close vicinity of protected areas or natural habitats. However, during the incipient stage of AF implementation, the selected list of priority investments for local communities (commune platforms for manure management) identified nine such facilities that are proposed to be located in the vicinity of within protected Natura 2000 sites. Natura 2000 network is the major outcome of European Union (EU) policies on biodiversity and is designed to protect species and habitats in accordance with the EU Habitats Directive (92/43/EEC 1992) and EU Birds Directive (2009/147/EC 2009). As EU member country, Romania set up Natura 2000 network which is covering about 23% from national territory in more than 600 sites. Presently, there are territorial administrative units (communes) in Romania completely or partially included in a Natura 2000 Natural Habitats (OP) (BP 4.04) Yes network. These deemed the need to implement environmental impact assessments before applying for development projects, including the ones financed under INPC-AF. For all the activities carried out in the perimeter and in the vicinity of the protected natural area, it is compulsory to respect the provisions of the management plans and the national regulations in force. Romania has the legislation on environmental impact assessment (EIA) fully aligned with EU policies, and the procedure for evaluating the impact on environment for any project (public or private) integrates the appropriate assessment of protected natural areas of Community interest, conservation of natural habitats, wild flora and fauna. The Romanian environmental protection authorities concluded, based on a detailed assessment and ecological survey carried out in 2018 by the local proponents at the level of feasibility study phase, that the proposed projects have no significant negative impact on the integrity of the protected natural areas. The same favorable The World Bank RESTRUCTURING ISDS Romania Integrated Nutrient Pollution Control Project (P093775) conclusions were issued by the custodians of the respective protected areas. The environmental agreements issued by the local EPAs are based on in-depth analyses of technical documentations submitted by the project proponents, on site visits of the proposed locations, and include certain conditions for the execution and operation of the proposed sub-projects in the respective Natura 2000 sites. The environmental agreements confirm that specific mitigation measures to avoid impacts to the natural habitats are included. The key most effective mitigation measure regarding protection of birds is ban on project construction during the nesting period (April 1 – July 1). These measures were introduced in the Ecological Surveys that assessed the proposed project’s impact on natural habitats and further in the site-specific ESMPs that were prepared by the local consultants that also prepared the feasibility studies for the respective investments. However, construction phase and to a lesser extend operation phase can have potential negative impacts on Natural Habitats. Therefore, the new sensitive proposed locations triggers application of OP 4.04 for mitigating the potential impacts of the project on protected habitats and species, and for proposing effective measures that will prevent degradation of natural habitats. OP 4.04 will apply to all investments located within or in a proximity to Natural 2000 sites. The Environmental Management Plan (EMP) approved for the project was revised accordingly to include specific mitigation measures to ensure effective compliance with the policy requirements. Site-specific ESMPs will be prepared to provide effective mitigation measures that will prevent degradation of natural habitats. Therefore, it can be assumed that in all sub-projects proposed for being located in Natura 2000 sites the expected impacts on natural habitats are considered to be minimal, and there will be no significant conversion or degradation of critical natural habitats. No important bird species for conservation will be affected by loss of breeding The World Bank RESTRUCTURING ISDS Romania Integrated Nutrient Pollution Control Project (P093775) habitat, and no critical habitats were identified within the projects area of influence. Forests (OP) (BP 4.36) No Pest Management (OP 4.09) No Although this safeguard will not be triggered, the environmental screening process will screen for the Physical Cultural Resources (OP) (BP 4.11) No presence of physical cultural resources. In addition, chance find procedures will be included in all works contracts. Indigenous Peoples (OP) (BP 4.10) No The proposed investments will continue to take place exclusively on municipally owned land. Robust screening mechanisms are in place to avoid impacts covered under OP 4.12 pertaining to formal or informal users. The Guide for Applicants, Involuntary Resettlement (OP) (BP 4.12) No Concept Note and Full Applications to be used by participating communes and municipalities include a description of status and current uses of the land (including for tree planting) to ensure impacts covered under OP 4.12 are avoided. Safety of Dams (OP) (BP 4.37) No The project will support activities that take place on transboundary waterways as defined in OP 7.50. (i.e. the whole territory of Romania drains into the Black Sea and Danube River Basins). It is anticipated that investments will not (i) cause appreciable harm to the other riparian as it will not adversely change the quality or quantity of water flows, and (ii) it will not be appreciably harmed by the other riparian possible water use. The Project will serve existing populations that are already consuming water from Projects on International Waterways (OP) the same river basins. There will be no increase in Yes (BP 7.50) water abstraction or consumption, no new agro- processing facilities which may involve intake of water from the Danube River or its tributaries funded under the Project. . Exception to the notification requirements of OP 7.50 has been granted because the proposed activities do not attempt to modify waterways nor significantly increase water abstraction volumes, leaving the water rights of other riparian countries unaffected. On the contrary, in terms of the “potential pollution� issue, the project activities are designed The World Bank RESTRUCTURING ISDS Romania Integrated Nutrient Pollution Control Project (P093775) to a betterment of the quality of their waters. Also, in terms of the “use of� issue, the project investments will involve separating, proper storing and recycling of animal waste so that its discharge into the water bodies that drain into the Danube River or the Danube River itself is reduced. Animal waste treatment facilities funded under the project will not involve any intake of river water. Projects in Disputed Areas (OP) (BP 7.60) No KEY_POLICY_TABLE II. KEY SAFEGUARD POLICY ISSUES AND THEIR MANAGEMENT A. SUMMARY OF KEY SAFEGUARD ISSUES 1. Describe any safeguard issues and impacts associated with the Restructured project. Identify and describe any potential large scale, significant and/or irreversible impacts. The project (additional financing) has no significant and/or irreversible impact. Its only minor impact will be temporary nuisances resulting from construction activities, and may include: (i) increased pollution due to construction waste; (ii) generation of dust, noise, and vibration due to the movement of construction vehicles and machinery; (iii) associated risks due to improper disposal of construction waste, or minor operational or accidental spills of fuel and lubricants from the construction machinery; (iv) improper reinstatement of construction sites upon completion of works. All these potential environmental impacts are readily identifiable, small in scale, and minimal in impact and can be effectively prevented, minimized, or mitigated by including into the work contracts specific measures to be taken by contractors. The project design aims to have a positive effect on the environment as measured by improved water quality. A limited number of sub-projects (manure management platforms) are going to be located within nature protected areas Natura 2000. Despite the fact that both the construction phase and the operation phase of the sub-projects are expected to have minor impacts on the environment, natural habitats and species, application of OP 4.04 was added to eliminate degradation of natural habitats and protected species. OP 4.04 will apply to sub-projects located within or in a short proximity to Natura 2000 sites, and it will be reflected in the respective site-specific ESMPs. Since the project supported activities will take place on transboundary waterways, OP 7.50, will be triggered. However, project interventions are not expected to adversely affect water quality or quantity to downstream riparian states. It is anticipated that activities will not (i) cause appreciable harm to the other riparian states as it will not adversely change the quality or quantity of water flows, and (ii) will not be appreciably harmed by other riparian states possible water use. Exception to the notification requirements of OP 7.50 has been granted because the proposed activities do not attempt to modify waterways nor significantly increase water abstraction volumes, leaving the water rights of other riparian countries unaffected. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area. The long-term environmental impacts anticipated are positive and linked to the overall project development objectives to reduce nutrients concentrations in surface and ground water bodies. The World Bank RESTRUCTURING ISDS Romania Integrated Nutrient Pollution Control Project (P093775) 3. Describe any potential alternatives (if relevant) considered to help avoid or minimize adverse impacts. n/a 4. Describe measures taken by the borrower to address safeguard policy issues. Provide an assessment of borrower capacity to plan and implement the measures described. The required mitigation measures for the AF project activities are standard and widely used in construction practices. They were already well prescribed in the Environmental Management Plan (EMP) which was prepared for the original project. Whereas the AF project will support the same types of activities as under the original project, the exiting EMP was updated, approved and disclosed in December 2015, and further applied also for this new project. Triggering of OP 4.04 will be limited to a few sub-projects located within or in a short proximity to Natura 2000 sites. It will require additional specialist input to the site-specific ESMPs in terms of ecological survey, assessment of impacts on protected habitats and species, and respective mitigation measures preventing degradation of natural habitats and species. Therefore, with the project restructuring for triggering the OP/BP 4.04 safeguard policy, the approved EMP was updated adequately as to include the specific conditions and requirements related to the protection of natural habitats and Natura 2000 sites as requested by the national legislation and by the Bank safeguard policy – OP 4.04 Natural Habitats; this revised document was re-disclosed locally and on the Bank’s website. The actual EMP stipulates all contracts for construction works will include requirements for implementation of the specific measures as per EMP provisions and good construction practices. Environmental issues including mitigation measures would be supervised periodically by the PMU M&E Staff supported by the technical support staff located in each of the Water Basin Directorates, and by specialized consultants. The local (county) environmental protection agency and water inspectorate would also be involved in supervision of construction work and operations. The project will rely on the Romanian laws (fully aligned with the EU environmental acquis) governing the process for environmental permitting and review. The implementing agency (MWF through the PMU) is responsible for project preparation and implementation given its long experience with Bank-financed operations, capacity in following Bank procurement, financial management and safeguard procedures. the PMU has built a positive track record in safeguards monitoring and compliance throughout the implementation of actual project. The PMU will carry out project implementation in close cooperation with the participating communes and key counterparts and will be responsible for managing the implementation of the project, including the continuous monitoring and evaluation, the control of safeguards compliance, as well as routine communications with the World Bank. 5. Identify the key stakeholders and describe the mechanism for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. Key stakeholders are commune residents/farmers in nitrate vulnerable zones, local commune administrations, and county administrations who are responsible for the promotion of investments to help improve environmental conditions and raising awareness of the local population on behavior change. During sub-projects preparation consultations will be conducted in the respective participating communes. PMU will carry out public consultations for groups that may be impacted by subprojects before finalization of site- specific ESMPs. These groups are usually represented by those who live near construction site, as well as by representatives of local NGOs, and other stakeholders. PMU will conduct at least one public consultation with groups affected by the activity prior to completion of the individual, site-specific ESMPs. DISCLOSURE_TABLE B. DISCLOSURE REQUIREMENTS The World Bank RESTRUCTURING ISDS Romania Integrated Nutrient Pollution Control Project (P093775) ENV_TABLE Environmental Assessment/Audit/Management Plan/Other Date of receipt by the Bank Date of submission for disclosure 20-Sep-2019 30-Sep-2019 For Category ‘A’ projects, date of distributing the Executive Summary of the EA to the Executive Directors “In country� Disclosure Country Date of Disclosure Romania 27-Sep-2019 Comments COMPLIANCE_TABLE C. COMPLIANCE MONITORING INDICATORS AT THE CORPORATE LEVEL EA_TABLE OP/BP/GP 4.01 - Environment Assessment Does the project require a stand-alone EA (including EMP) report? Yes If yes, then did the Regional Environment Unit or Practice Manager (PM) review Yes and approve the EA report? Are the cost and the accountabilities for the EMP incorporated in the credit/loan? Yes NH_TABLE OP/BP 4.04 - Natural Habitats Would the project result in any significant conversion or degradation of critical No natural habitats? If the project would result in significant conversion or degradation of other (non- critical) natural habitats, does the project include mitigation measures Yes acceptable to the Bank? PIW_TABLE OP 7.50 - Projects on International Waterways Have the other riparians been notified of the project? NA The World Bank RESTRUCTURING ISDS Romania Integrated Nutrient Pollution Control Project (P093775) If the project falls under one of the exceptions to the notification requirement, has this been cleared with the Legal Department, and the memo to the RVP Yes prepared and sent? Has the RVP approved such an exception? Yes PDI_TABLE The World Bank Policy on Disclosure of Information Have relevant safeguard policies documents been sent to the World Bank for Yes disclosure? Have relevant documents been disclosed in-country in a public place in a form and language that are understandable and accessible to project-affected groups Yes and local NGOs? ALL_TABLE All Safeguard Policies Have satisfactory calendar, budget and clear institutional responsibilities been Yes prepared for the implementation of measures related to safeguard policies? Have costs related to safeguard policy measures been included in the project Yes cost? Does the Monitoring and Evaluation system of the project include the monitoring Yes of safeguard impacts and measures related to safeguard policies? Have satisfactory implementation arrangements been agreed with the borrower Yes and the same been adequately reflected in the project legal documents? III. APPROVALS Task Team Leader(s) Cesar Niculescu Approved By Safeguards Advisor Nina Chee 07-Oct-2019 Practice Manager/Manager Kseniya Lvovsky 07-Oct-2019 .