INTEGRATED SAFEGUARDS DATA SHEET APPRAISAL STAGE Report No.: ISDSA2854 Public Disclosure Copy Date ISDS Prepared/Updated: 01-Apr-2013 Date ISDS Approved/Disclosed: 11-Apr-2013 I. BASIC INFORMATION 1. Basic Project Data Country: Bangladesh Project ID: P132634 Project Name: Bangladesh Safety Net Systems for the Poorest Project (P132634) Task Team Iffath Anwar Sharif Leader: Estimated 17-Apr-2013 Estimated 20-Jun-2013 Appraisal Date: Board Date: Managing Unit: SASSP Lending Specific Investment Loan Instrument: Sector(s): Other social services (100%) Theme(s): Other accountability/anti-corruption (15%), Social safety nets (70%), Vulnerability assessment and monitoring (15%) Is this project processed under OP 8.50 (Emergency Recovery) or OP No 8.00 (Rapid Response to Crises and Emergencies)? Financing (In USD Million) Public Disclosure Copy Total Project Cost: 2670.00 Total Bank Financing: 500.00 Total Cofinancing: Financing Gap: 0.00 Financing Source Amount BORROWER/RECIPIENT 2170.00 International Development Association (IDA) 500.00 Total 2670.00 Environmental B - Partial Assessment Category: Is this a Yes Repeater project? 2. Project Objectives The Project Development Objective is to improve the equity, efficiency and transparency of major social safety net programs to benefit the poorest households. 3. Project Description The Project Development Objective is to support major social safety net programs in Bangladesh to Page 1 of 8 improve their equity, efficiency, and transparency. To meet its objectives, the project will focus on achieving results for five safety net programs of Public Disclosure Copy Ministry of Disaster Management and Relief (MoDMR) in the following three intermediate areas: (i) improve targeting of program resources to the poorest households to promote more pro- poor coverage; (ii) strengthen management, program information systems and monitoring capacity to ensure efficient administration; and (iii) strengthen governance and accountability measures for increased transparency. These results be achieved under the proposed project's three components: (i) support to MoDMR safety net programs (EGPP, FFW, TR, GR and VGF) by financing a portion of program costs (cash payments) in line with progress against a set of disbursement linked indicators (DLIs); (ii) strengthening of MoDMR program administration and transparency; and (iii) development of the Bangladesh Poverty Database. The first component would reimburse the GoB for results, while the second two components can be seen as a financing instrument for the inputs needed to achieve the results under component 1. These two latter components will finance all inputs such as personnel, design of IT systems as well as hardware, monitoring systems, vehicles and other equipment, consultants, and incremental operating costs. Component 1: Support to MoDMR Safety Net Programs (total estimated cost US$430 million) The objective of this component is to support improvements in five safety net programs implemented under the MoDMR and provide co-financing for a share of the total consolidated expenditures of cash wage payments under EGPP and TR (from January 2014 – December 2017). Financing will be provided against progress on 8 DLIs which will support results in three areas: (i) improving the targeting of program resources to the poorest areas and households to promote more pro-poor coverage; (ii) strengthening management, program information systems and monitoring capacity to ensure efficient administration; and (iii) strengthening governance and accountability measures for increased transparency. Public Disclosure Copy Component 2: Strengthening of MoDMR program administration and transparency (total estimated cost US$30 million) The objective of this component is to strengthen the MoDMR/Department of Disaster Management's (DDM) institutional capacity to implement these programs efficiently and transparently, and thus can be seen as a financing instrument for the inputs needed to meet the DLI targets under component 1. Activities financed under this component include: (i) preparation of the overall Operations Manual based on the revised guidelines for the implementation of the DDM programs (EGPP, FFW, TR, VGF and GR); (ii) development of the specifications for the consolidated program MIS that will include a full set of modules including selection and verification of eligible beneficiaries, registration of selected beneficiaries, payments/transfers, case management, grievances and appeals; (iii) improving program monitoring at the field level; (iv) strengthening program management with the help of a consolidated program MIS; and (v) conducting evaluation reports. Component 3: Development of the Bangladesh Poverty Database – Bangladesh Bureau of Statistics (BBS) (total estimated cost US$40 million) This component will support BBS in the development of the Bangladesh Poverty Database (BPD) that will be used to better target the poor in DDM programs, and by other key safety net programs implemented by other Government agencies. The BPD would consist of a set of uniform, objective and transparent criteria to select the poor, and is expected to reduce the overall costs and errors Page 2 of 8 associated with targeting. This Database consisting of roughly 34 million households, of which around 10 million can be expected to be poor, and about 12 million vulnerable households who live just above the poverty line, will also help in improving the coordination, efficiency and effectiveness Public Disclosure Copy of all Social Safety Nets (SSNs). 4. Project location and salient physical characteristics relevant to the safeguard analysis (if known) The project will be implemented nationwide and the exact locations of sub-projects cannot be determined at this stage. 5. Environmental and Social Safeguards Specialists Shakil Ahmed Ferdausi (SASDI) Sabah Moyeen (SASDS) 6. Safeguard Policies Triggered? Explanation (Optional) Environmental Assessment OP/ Yes Environmental Category: B Partial Assessment BP 4.01 The project has triggered ‘Environmental Assessment OP/BP 4.01’ to avoid potentially adverse environmental impacts and enhance environmental outcomes in sub-project implementation. The project will be implemented allover Bangladesh and site selection is important in order to avoid any environmentally sensitive areas. Although the project is not expected to create any major impact, improper planning and implementation of the physical interventions may have localized environmental impacts, which will mostly be short-term and reversible. Considering Public Disclosure Copy the nature and magnitude of potential environmental impacts and scale of community level infrastructure development, the SNSP is classified as category ‘B’. Natural Habitats OP/BP 4.04 No Forests OP/BP 4.36 No Pest Management OP 4.09 No Physical Cultural Resources OP/ No BP 4.11 Indigenous Peoples OP/BP 4.10 Yes The project will be implemented nationwide. Since the location of the sub-projects is not known at this stage, there is a possibility of triggering OP 4.10 should the sub-projects be implemented in tribal areas or areas where Tribal Peoples are present. A Tribal Peoples Planning Page 3 of 8 Framework (TPPF) will be included as part of the Social Management Framework (SMF). The TPPF will guide the preparation of Tribal Public Disclosure Copy Peoples' Plans for sub-projects as and when required as well as guidance on disclosure processes. Involuntary Resettlement OP/BP No Based on the findings of the EGPP it has been 4.12 seen that no land acquisition or displacement of communities has been encountered. Hence the current project will not permit any sub-projects where there is a chance of land acquisition or displacement. These will be mentioned on a “negative list� in the SMF. Sub-project schemes will be screened at the proposal stage to establish that they do not trigger any land acquisition or displacement. Safety of Dams OP/BP 4.37 No Projects on International No Waterways OP/BP 7.50 Projects in Disputed Areas OP/BP No 7.60 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: Public Disclosure Copy The project comprises three components, of which two components are TA support and are not expected to have any environmental impact. Component 1 will support the safety net programs under the DDM, namely TR and EGPP, however the TA inputs will be provided to all programs, and thereby support FFW. FFW basically supports construction and maintenance of basic rural infrastructure and create rural employment during slack/lean periods and the rainy season. The sub-projects under FFW are largely construction and maintenance of rural roads, river embankments and irrigation channels. TR supports cleaning ponds/bushes and minor repair work to rural roads, schools, mosques and madrasa. EGPP is already being supported under an IDA and mainly covers earthen works such as (i) construction and maintenance of rural roads; (ii) excavation or re-excavation of irrigation canals and drains; (iii) construction and maintenance of earthen embankments; (iv) land-fill for community institutions like schools, mosque, pagoda, temple, graveyards, prayer grounds etc.; (v) earthen shelters to protect animals against cyclones; (vi) re-excavation of public ponds or fish firms; (vii) organic fertilizer production; (viii) further development of rural markets or helipad, and (ix) excavation or re-excavation of water reservoirs. The environmental impacts from the majority of sub-projects under SNSP are likely to be minor, local and, in most cases, temporary. Given that the workfare sub-projects are national programs, it is probable that they may impact areas with tribal people (TPs), thereby triggering the safeguards policy for Indigenous Peoples (OP Page 4 of 8 4.10). The scale and magnitude of social impacts expected under the project are minor. Since no land acquisition or displacement will be permitted under the project, no long term or irreversible impacts are expected. In rare cases where some soil may be required from adjacent plots for rural Public Disclosure Copy roads, it will be carried out under mutually agreed terms. The SMF clarifies and specifies these modalities. Appropriate consultation, communication strategies and modalities for consensus building and establishing feedback loops with Tribal Communities are spelled out in the SMF as part of the Tribal Peoples Planning Framework The SMF also looks at gender, participation and inclusion issues. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area: No long-term or indirect impacts are envisaged from the project interventions. 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. The sub-projects will be identified during the project implementation phase. The environmental and social screening along with the Environmental Code of Practice (ECoP) will help to consider the alternative options at the grassroots-level planning stage. 4. Describe measures taken by the borrower to address safeguard policy issues. Provide an assessment of borrower capacity to plan and implement the measures described. The Ministry for Disaster Management and Relief (MoDMR) and the Bank team have agreed that no land acquisition or displacement of communities (economic or physical) from private or public lands will be required and since most sub-projects will be carried out in rural settings where squatters are not widely found, no large scale displacement is expected. Land acquisition and displacement of communities/people will not be allowed and this requirement will be included in the program guidelines. Each sub-project proposal assessed by the Union Parishad - Project Implementation Committee/Humanitarian Assistance Implementation Committee (UP-PIC/HAIC) Public Disclosure Copy will include a social screening form that will demonstrate specifically that no acquisition or displacement is undertaken. Screening for TPs will also be part of the sub-project proposal screening format. The Environmental Management Framework (EMF) and Social Management Framework (SMF) prepared for the ongoing Employment Generation Program for the Poorest (EGPP), which is implemented by the same Ministry, has been reviewed and revised for the proposed project based on field assessments of EGPP sub-projects. The framework identifies and assesses the potential impacts under different sub-projects of the proposed project. The EMF and SMF details the criteria for community level environmental and social screening and planning, and sub-project level Environmental Code of Practice (ECoP) to mitigate possible negative environmental impacts. Community-level environmental and social screening will be an integral part of sub- project planning to understand possible impacts, and to identify concerns and ensure they are addressed early on to mitigate negative impacts or enhance opportunities. If any sub-project requires additional measures beyond what is already described in the ECoP, a simple Environmental Management Plan (EMP) will be prepared by the Union Parishad-Project Implementation Committee/Humanitarian Assistance Implementation Committee (UP-PIC/UP- HAIC) in consultation with the Project Implementation Officer (PIO) and Field Supervisor. Similarly, the SMF will guide the preparation of Social Management Plans in response to triggers pointed out by the screening process, i.e. if there is a need to prepare a Tribal Peoples Page 5 of 8 Development Plans and/or inclusion and participation action plans or gender action plans. The screening formats (environmental and social), ECoP and sample EMP will be included in the project Operations Manual (in Bangla) as part of the guidance to prepare and implement sub- Public Disclosure Copy projects. The PIO will be responsible for reviewing the environmental and social screening and mitigation measures of sub-projects. PIOs and Field Supervisors will also review environmental and social compliance as part of their regular monitoring activities and will maintain a database for sub-project specific environmental screening and mitigation measures. Given the large number of small-scale sub-projects, the implementing agency will involve an independent consultant (third party) to monitor compliance with the EMF and SMF and implementation of mitigation measures of sub-projects on random sampling basis. Lessons learned from the ongoing EGPP suggest that the implementing agency and other stakeholders have limited experience in environmental and social assessment and management. Component 2 will help strengthen DDM capacity in monitoring and evaluation of its programs. It was agreed that environmental management, social management climate change adaptation and disaster risk reduction will be included in the capacity building program for PIOs and Field Supervisors. In addition, the project will organize several orientation programs on the Operations Manual, including screening and ECoP. 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. The Environmental Management Framework (EMF) and Social Management Framework (SMF) have been drafted by the Ministry of Disaster Management and Relief (MoDMR) in consultation with local communities where sub-projects are implemented. A draft EMF/SMF have been disclosed on the Ministry website on April 8, 2013, with hard copies provided in the implementing agency's office, for comments from the public before finalization. Public Disclosure Copy B. Disclosure Requirements Environmental Assessment/Audit/Management Plan/Other Date of receipt by the Bank 07-Apr-2013 Date of submission to InfoShop 09-Apr-2013 For category A projects, date of distributing the Executive Summary of the EA to the Executive Directors "In country" Disclosure Bangladesh 08-Apr-2013 Comments: Draft EMF disclosed on MoDMR website (www.dmrd.gov.bd) and hard copies available in implementing agency office. Indigenous Peoples Development Plan/Framework Date of receipt by the Bank 07-Apr-2013 Date of submission to InfoShop 09-Apr-2013 Page 6 of 8 "In country" Disclosure Bangladesh 08-Apr-2013 Comments: Draft SMF (including Tribal Peoples Development Plan) disclosed on MoDMR Public Disclosure Copy website (www.dmrd.gov.bd) and hard copies available in implementing agency office. If the project triggers the Pest Management and/or Physical Cultural Resources policies, the respective issues are to be addressed and disclosed as part of the Environmental Assessment/ Audit/or EMP. If in-country disclosure of any of the above documents is not expected, please explain why: C. Compliance Monitoring Indicators at the Corporate Level OP/BP/GP 4.01 - Environment Assessment Are the cost and the accountabilities for the EMP incorporated Yes [ ] No [ ] NA [ ] in the credit/loan? OP/BP 4.10 - Indigenous Peoples If the whole project is designed to benefit IP, has the design Yes [ ] No [ ] NA [ ] been reviewed and approved by the Regional Social Development Unit or Sector Manager? The World Bank Policy on Disclosure of Information Have relevant safeguard policies documents been sent to the Yes [ ] No [ ] NA [ ] World Bank's Infoshop? Have relevant documents been disclosed in-country in a public Yes [ ] No [ ] NA [ ] place in a form and language that are understandable and accessible to project-affected groups and local NGOs? All Safeguard Policies Public Disclosure Copy Have satisfactory calendar, budget and clear institutional Yes [ ] No [ ] NA [ ] responsibilities been prepared for the implementation of measures related to safeguard policies? Have costs related to safeguard policy measures been included Yes [ ] No [ ] NA [ ] in the project cost? Does the Monitoring and Evaluation system of the project Yes [ ] No [ ] NA [ ] include the monitoring of safeguard impacts and measures related to safeguard policies? Have satisfactory implementation arrangements been agreed Yes [ ] No [ ] NA [ ] with the borrower and the same been adequately reflected in the project legal documents? III. APPROVALS Task Team Leader: Iffath Anwar Sharif Approved By Regional Safeguards Name: Date: Coordinator: Page 7 of 8 Sector Manager: Name: Pablo Gottret (SM) Date: 11-Apr-2013 Public Disclosure Copy Public Disclosure Copy Page 8 of 8