INTEGRATED SAFEGUARDS DATA SHEET APPRAISAL STAGE Report No.: ISDSA6998 Public Disclosure Copy Date ISDS Prepared/Updated: 13-Jan-2014 Date ISDS Approved/Disclosed: 15-Jan-2014 I. BASIC INFORMATION 1. Basic Project Data Country: Haiti Project ID: P144614 Project Name: Cultural Heritage Preservation and Tourism Sector Support Project (P144614) Task Team Sylvie Debomy Leader: Estimated 13-Jan-2014 Estimated 20-Mar-2014 Appraisal Date: Board Date: Managing Unit: LCSDU Lending Investment Project Financing Instrument: Sector(s): General public administration sector (50%), Other domestic and international trade (35%), General water, sanitation and flood protec tion sector (15%) Theme(s): Cultural Heritage (60%), Urban services and housing for the poor (15%), Other urban development (10%), Micro, Small and Medium Enter prise support (10%), Other public sector governance (5%) Is this project processed under OP 8.50 (Emergency Recovery) or OP No 8.00 (Rapid Response to Crises and Emergencies)? Public Disclosure Copy Financing (In USD Million) Total Project Cost: 45.00 Total Bank Financing: 40.00 Financing Gap: 5.00 Financing Source Amount BORROWER/RECIPIENT 0.00 IDA Grant 40.00 Total 40.00 Environmental B - Partial Assessment Category: Is this a No Repeater project? 2. Project Development Objective(s) The Development Objectives of the Project is to contribute to inclusive development around key cultural heritage sites in the North of Haiti by upgrading selected heritage assets, strengthening local community infrastructures and promoting tourism sector development. Page 1 of 14 3. Project Description Component 1 – Cultural Heritage sites and touristic circuits in the National Historic Park (PNH- CSSR) and Cap-Haitien Historic City Center (US$24 million). Investments supported by this Public Disclosure Copy component would focus on the PNH and the historic center of Cap-Haitien. In the PNH, the Project would support conservation and management of cultural and natural sites that can drive and service potential tourist demand, enhancing the attractiveness of the destination and increasing the carrying capacity of the region, while reducing pressure on fragile assets such as the Citadelle Laferriere. In the first phase, the Project would support emergency works to deal with the imminent risks to the integrity of the Citadelle and the Palais Sans Souci, as determined by UNESCO in April 2012. These emergency works would include strengthening foundations, walls, and protecting assets against water infiltration. In parallel, the Project would finance strengthening the capacity of the ISPAN to manage cultural assets, establish a financially sustainable Park Authority, and develop a site master plan and management plan which would be financed under the Project. The management plan will assess best management practices to ensure financial sustainability but will also include spatial management aspects. In Cap-Haitien, the Project would finance targeted investment to upgrade the city’s historic core, with a blend of financing and technical assistance instruments to promote a network-oriented approach, focusing on some classified buildings, squares and streetscapes. The Project would also support the updating of building codes for the city center and the identification of restoration pilot zones where owners of buildings registered as heritage sites would be encouraged to conserve and adaptively reuse them for tourism. Other locations in the North may be added during the Project second phase. Moreover, activities to assess disaster risk would be financed and implemented in coordination with the United Nations Development Program (UNDP) for Disaster Risk Management. Component 2 - Local investments in Dondon, Milot and Cap Haitien (US$6 million). This component would fund investments to improve local urban infrastructure in localities and neighborhoods adjacent to the historical sites being upgraded under the project, to support inclusive growth out of tourism development. The eligible investments would be physical investment and Public Disclosure Copy service sub-projects of a public good nature, implemented at communal and inter-communal level in Milot and Dondon, the adjacent communes of the PNH-CSSR and gateways to the Park, and in the Cap Haitian ne ighborhoods around the historic city core. The project would also fund sanitation studies and the required support to assist in sub-project prioritization, and follow-up, as well as basic means for the municipalities to strengthen their capacity to support the participatory process. The participatory decision-making frameworks and mechanisms developed under the Transport and Territorial Development Project (PTDT, P095523), including the “Communal Consultation Table”, would be used to prioritize and approve the eligible local investment sub-projects. These sub-projects would be “structuring” socio-economic investments relating to the tourism value chain directly or indirectly. They would have to be vetted by the Communal Consultation Table and included in the communal development plan. Municipalities would be allocated an indicative financial envelope. The approval of sub-project proposals, and release of funds would, be predicated on the preparation of a management and maintenance plan and a cost-benefit analysis. Potentially eligible investments include: street lighting and paving, upgrading of sidewalks, drainage and sanitation improvement, upgrade of public squares, façade embellishment, tree planting, and water network extension. Detailed eligibility and selection criteria for the local/communal investments would be described in the Operational Manual. These investments would complement community driven development activities in the framework of the Urban Community Driven Development Project (PRODEPUR, P106699). Page 2 of 14 Component 3 – Inclusive Tourism Sector Development (US$4 million). The objective of this component is to support tourism sector development for the North of Haiti that leverages the cultural Public Disclosure Copy heritage assets in the region through tourism planning, product development, support to tourism enterprises, community engagement and institutional capacity building. The component aims to support and mobilize the public and private sector actors in the North Haiti tourism sector by financing, inter alia, technical assistance to the Destination Management Organization (DMO) and the Ministry of Tourism. Technical assistance would include: support for tourism planning, development of tourism products (e.g. activities, excursions), marketing and promotion and community engagement in the development of these products. This support would enable the primary public and private actors in the North Haiti tourism sector to commercialize and position touristic products and services in domestic, regional and international markets. It would also provide support to enterprises in the tourism sector, with support ranging from enabling basic business establishment to product development and marketing. The component would also develop and implement a community tourism fund designed to, inter alia, develop and manage local festivals and cultural events in order to engage local populations in cultural heritage tourism. Finally, the Project would finance the upgrading and implementation of the Ministry tourist sector statistics system to orient all actors in the North Haiti tourism sector towards a more strategic and evidence-based approach to the development of the region’s touristic products, markets and support services. Component 4 - Contingent Emergency Response Component (US$1 million). Due to the high risk of a catastrophic event in Haiti (particularly geotechnical (earthquakes, tsunamis, soil liquefaction, and landslides), hydro-meteorological (wind/hurricanes, cyclone, and tsunami), and climate-change- related (sea level rise and coastal erosion), the proposed project would include a provisional component, designed as a mechanism that would allow for rapid response in the event of an eligible emergency. Such components, which include triggers and conditions for the use of funds, are included in most investment projects in Haiti in keeping with the recommendations of the 2011 WDR on Fragility and with the operational experience acquired in Haiti since the 2010 earthquake. Subject to the request of the Government and prior approval of an Operational Manual, this Public Disclosure Copy component would support the execution of emergency recovery and rehabilitation sub-projects or the implementation of a subsidy scheme for eligible beneficiaries affected by the emergency. If this component is triggered, all expenditures would be in accordance with OP/BP 10.00 and would be appraised, reviewed, and found to be acceptable to the Bank before any disbursement is made. If not disbursed 24 months before the closing date, the currently allocated amount of US$1 million can be made available to finance activities under the other Project components. Component 5 - Project Implementation, Monitoring and Evaluation (US$5 million). The Project would be implemented by the existing Technical Implementation Unit (Unité Technique d’Exécution) at the Ministry of Economy and Finance (MEF). The Project would also finance a dedicated ISPAN team in charge of technical oversight of Component one. Under this component 5, the project would finance goods, operating costs, and services needed to ensure effective project implementation, supervision, safeguards and financial management, as well as needed expenses to ensure proper monitoring and evaluation. This component would strengthen management capacity in the areas of management, procurement, and financial management. 4. Project location and salient physical characteristics relevant to the safeguard analysis (if known) The project activities and investments would take place in the North of the country, mainly in the National Historic Park and the adjacent communes and in Cap Haitien. These investments would be Page 3 of 14 coordinated with the Haiti Business Development and Investment project which includes a component on Business Development Services for MSME in the North, with the Infrastructure & Institutions Emergency Recovery which includes local road rehabilitation to touristic areas and Public Disclosure Copy investments in the Cap Haitien airport, the Urban Community Driven Development Project (PRODEPUR) which finances local and community drive investments and initiatives, and the Rebuilding Energy Infrastructure and Access Project, which could finance lightning and electrification of the PNH-CSSR buildings, Milot, Dondon and the center of Cap Haitien. The area around the Citadelle and the Citadelle itself is known to be one of the few natural habitats left in Haiti, and the National Historic Park qualifies as a critical natural habitat under OP 4.04. At least 15 species of plants and animals listed as critically endangered, endangered, or vulnerable on the IUCN Red List have been recorded in the area. Birdlife International formally recognizes the site as an Important Bird Area (Citadelle-Sans Souci-Ramiers). This area is surrounded by largely secondary forest with some primary forest, but people have settled along the roads through the park as well as within the forest itself. Direct negative impacts from the project to the forest are unlikely since the proposed Project does not intend to cut any trees in this vicinity and the works would occur on isolated buildings in the park that have few to no trees around them. Indirect negative impacts could occur if tourist development in the area attracts crowds to the area and without protection of the vicinity; people may attempt to build structures in this vicinity which may then lead to further development such as roads, pavements, etc. The development of a Park Business Plan and the establishment of a Park Authority include provisions to avoid or mitigate these indirect negative impacts and contribute to the sustainable protection of the forest. These mitigation measures may include restrictions on the access to and use of the NHP’s natural resources and result in direct negative social impacts such as loss of assets, temporary or permanent income generation and economic displacement Citadel Laferriere and the Palais du Sans Souci are World Cultural Heritage Sites and may be impacted by the upgrading investments in the zone, increasing visitation to the site, an influx of new residents to the area, negative aesthetic impacts, more residential construction close the areas, and a Public Disclosure Copy potential increase in vandalism and erosion of the sites. The socially inclusive investments in Milot and Dondon, two communities at the entrances to the National Historic Park may result in limited involuntary resettlement and potential temporary loss of income. The historic core of Cap Haitien is occupied by a vibrant community of different social and economic backgrounds and can be heavily congested in terms of traffic. No direct negative impacts are expected from the project, but indirect negative impacts may include social tension with potential former inmates of the prison, often victims of the Duvalier regime, if the reuse of the site is not openly discussed between the stakeholders, increased congestion on the roads from increased tourist numbers, buses etc. with reduced air quality, increase in crime, violence and negative social behavior. 5. Environmental and Social Safeguards Specialists Nyaneba E. Nkrumah (LCSEN) Peter F. B. A. Lafere (LCSSO) 6. Safeguard Policies Triggered? Explanation (Optional) Page 4 of 14 Environmental Assessment OP/ Yes The Environmental Assessment (OP/BP 4.01) BP 4.01 policy is triggered due to the potential for adverse social and environmental impacts under the Public Disclosure Copy project's main components. Based on the proposed scope of the project activities, the project is proposed as an environmental risk Category B. Investments which would normally be considered as A-type investments would not be eligible for financing. Under Component 1, different types of negative environmental impacts are possible relating to infrastructure investments that would be supported by this project:(i) impacts from civil works associated with restoration and excavation of historical monuments in Cap Haitian (ii) impacts from new construction; (iii)impacts associated with occupational health and safety (e. g., noise, changes in traffic patterns, dust, possible contaminants in the dust, etc (iv) assessment of other social impacts not associated with resettlement or land acquisition. The environmental impacts associated with construction works are likely to be limited in time and space, and actions to minimize and mitigate have been included in the project's ESMF and EMP. Public Disclosure Copy Under component 2, there would be a number of local level investments. These are locally driven investments and currently their location and exact nature are not yet known. The ESMF would be applied to those works or activities not yet agreed to be financed under the project. These may include under investments to promote tourist value chains (artisan market, water and sanitation, lighting, handicrafts, food products, street lighting, river cleaning, etc). Component 3 would focus on tourism related activities and investments may include grant activities for public and private actors in the tourism sector to commercialize and position touristic products and services. The ESMF would screen each of these activities, and an EMP would be developed for them where necessary. In addition, a manual of procedures would be developed for screening grant applications similar to those developed for small grant programs in Haiti. This is to ensure that the environmental Page 5 of 14 and social screening process is a key part of the grant selection process. Component 4 and 5 are not likely to trigger Natural Habitats OP/BP 4.04 Yes The Natural Habitats (OP/BP 4.04) policy is triggered because the area around the PNH is known to be one of the few remaining natural Public Disclosure Copy habitats left in Haiti. The area surrounding the PNH qualifies as a critical natural habitat under OP 4.04. At least 15 species of plants and animals listed as critically endangered, endangered, or vulnerable on the IUCN Red List have been recorded in the area. Birdlife International formally recognizes the site as an Important Bird Area (Citadelle-Sans Souci- Ramiers). However, despite this, the project would finance works specific to historical buildings in the PNH and does not intervene directly in the natural habitat areas around the historic buildings. In fact, the work sites have few or no trees. It is therefore expected that the project impact on the natural habitat would be limited. Any negative impacts would be greatly reduced by mitigation measures proposed in the ESMF and subsequent EMPs. The main impact on the Natural Habitat, therefore, would be indirect. The project hopes to increase tourism to the area. This increased tourism would impact the natural surroundings if vendors and others either relocate closer to the PHN to gain access to tourists or if they begin to unsustainably use natural resources and forest products for crafts. Public Disclosure Copy To ensure that these possible impacts do not happen, the Project would work to ensure that the business/management planning for the parks takes into account these possible impacts. As a first step, to be completed by CNGIS by the end of first quarter 2014 is an environmental and social baseline study of the park. As a second step, the Bank would review this document and any gaps in the document would be financed by the Project. The baseline study would help guide and green the business planning (and later, implementation of the plan) for the National Historic Park. Essentially, the baseline study would guide where development under the project can occur, and where it cannot. As a third step, the approved study will serve as an input into the business/management plan for the PHN. Finally, the project will ensure that this is carried through into implementation of the plan. Page 6 of 14 Forests OP/BP 4.36 Yes The Forests (OP/BP 4.36) policy is triggered because of the baseline study which would influence the manner in which forests are Public Disclosure Copy managed around the PNH but also because forests could directly be negatively impacted by an increase in tourists to the area (see section on OP 4.04). As mentioned previously, the baseline study would serve as an input into the park business/management plan and would impact where and how development occurs in these touristic sites. Any potential negative impact on Forest would be reduced by implementing the mitigation measures proposed within the ESMF and the subsequent EMPs. Pest Management OP 4.09 Yes It is possible that herbicides and biocides would be used to clean the walls of the Citadelle. A Pest Management Plan (PMP) is not required at this stage because the work would largely be done manually, with only small quantities of herbicides and biocides, if needed. While a PMP is not needed, the ESMF (Annex 4) contains a pesticide screening tool that, as per Bank guidance, would "screen pest control products to establish a list of pesticides authorized for procurement under the project." According to Bank guidelines, screening is appropriate when expected quantities are not significant from a health or environmental standpoint, there are not significant Public Disclosure Copy environmental or health concerns, no hazardous products would be introduced and the project would not introduce pesticide use into an area where there has been no use or significantly increase the level of pesticides. Physical Cultural Resources OP/ Yes The Physical Cultural Resources (OP/BP 4.11) BP 4.11 policy is triggered because of the planned catalytic investments in the Northern Zone to upgrade the Cultural Heritage infrastructure at the National History Park, a UNESCO World Heritage Site which includes the Citadelle Laferriere and the Palais du Sans Souci. The ESMF screens out activities that may negatively impact the site, as well as details criteria for identifying and managing all other social and environmental impacts to the site, including those arising from increasing visitation to the site, an influx of new residents to the area, negative aesthetic impacts, and a potential increase in Page 7 of 14 crime and violence. A Physical and Cultural Resources Framework Public Disclosure Copy has been prepared, consulted and disclosed to ensure that there is adequate assessment of physical and cultural resources and that any residual impacts are appropriately mitigated. In addition, the Physical and Cultural Resources Framework elaborates on the type of consultation necessary to ensure that there is sufficient consultation with international (including UNESCO), national and local stakeholders regarding these Historic sites. Finally, chance finds procedures will be described in the Plan to safeguard any cultural resources that may be discovered during works or services performed under the project under any of its components. Indigenous Peoples OP/BP 4.10 No The policy is not triggered since there are no indigenous people in this area. Involuntary Resettlement OP/BP Yes This policy is triggered because (i) the inclusive 4.12 local investments of Component 2 may require limited temporary or permanent involuntary resettlement or land acquisition, and (ii) the Park Management Plan for the National Historic Park may include restrictions on the access and use of natural resources within the boundaries of the Park. Public Disclosure Copy The socially inclusive investments in Milot and Dondon, the two communities at the entrances of the National Historic Park, may result in limited involuntary resettlement and potential temporary loss of income . It is unlikely that the investments in Cap Haitien would result in involuntary resettlement, but indirect negative impacts may include temporary loss of income for the market sellers and traders around the historic sites. Mitigation measures for involuntary resettlement would be identified in consultation with the affected people, and would include the possibility of in-kind compensation based on experiences with urban rehabilitation works in Port-Au- Prince. Because the activities to support inclusive local investments will only be identified using a participatory approach during project Page 8 of 14 implementation, a Resettlement Policy Framework (RPF) has been prepared in accordance with OP4.12 to assess and mitigate Public Disclosure Copy the involuntary resettlement impacts in Milot, Dondon and Cap Haitien, such as economic displacement and impacts on assets. The RPF would reflect the following principles: - Prior to the approval of sub-projects, the client will need to ensure that the sites, boundaries and ownerships of the relevant land plots are clearly identified and confirmed using a community- based mapping exercise that goes beyond simply checking for legal title. - In case there is resettlement, agreement on the compensation scheme and its payment or realization would be settled prior to the commencement of that particular sub-project. - In cases where there are disputed claims to eligibility to compensation or to land ownership or use, conflict resolution would be facilitated by the client, and though works may begin, proper compensation would be kept in escrow until the conflicts are resolved. In cases where this does happen, the client would remain in constant contact with the affected people and apply the best available dispute resolution mechanisms in the country. Public Disclosure Copy Given the objective to spur regional development, all upstream support that may spur downstream impacts on resettlement, as defined by the policy (e.g. through the preparation of bidding documents, etc.) would include reference to the principles of OP 4.12 in terms of, among other things, eligibility for compensation, asset valuation methodologies, and consultation and participation. A Process Framework (PF) was developed to safeguard potentially affected populations from restrictions to access and use of natural resources in the park The PF describes the process by which potentially affected populations can participate in the design and implementation of potentially necessary restrictions to the access and use of natural resources. It establishes criteria to Page 9 of 14 identify affected persons and the measures to assist them in improving or restoring their livelihoods while maintaining the sustainability of Public Disclosure Copy the Park. The implementation of the PF will inform the development of the Park Management Plan and its recommendations will be included in it. A Social Assessment will further identify key stakeholders and eligible groups who live in and around the park and/or who depend on the park resources, how these people will potentially be affected positively and/or negatively, and what measures need to be in place to ensure that their wellbeing is given utmost priority. Safety of Dams OP/BP 4.37 No The policy is not triggered since the proposed Project would not invest in dams nor would any project activities rely on the operations of existing dams. Projects on International No The policy is not triggered since Project activities Waterways OP/BP 7.50 would not affect any known International Waterways. Projects in Disputed Areas OP/BP No The policy is not triggered since Project activities 7.60 would not affect any known disputed areas. II. Key Safeguard Policy Issues and Their Management A. Summary of Key Safeguard Issues Public Disclosure Copy 1. Describe any safeguard issues and impacts associated with the proposed project. Identify and describe any potential large scale, significant and/or irreversible impacts: The project would invest in the National History Park World Heritage Site which is one of the few natural habitats remaining in Haiti and which qualifies as a critical natural habitat under OP 4.04. However, the actual works on the buildings, a key focus of the project, would be far from the natural habitat. Therefore, there is little potential for any large scale, significant or irreversible impacts on the species or the plant life. In 1985 (last siting) there were a few frogs found in and around the grounds of the Citadelle that belonged to a species of critically endangered frog (Eleutherodactylus poolei). While it is unlikely that the frog still exists in the building almost 30 years later, a baseline study of the park and its habitat is almost complete that focuses on describing and quantifying to the extent possible, the natural habitat of the area. The study would serve as an input into the business/management plan for the Citadelle and its surrounding historic sites. The Citadel Laferriere, Ramiers and the Souci Palace are the main historic buildings in the National History Park World Heritage Site and qualify as Physical Cultural Resources under OP 4.11. Structural strengthening and conservation works are undertaken precisely to avoid further degradation of the site and avoid large scale, significant or irreversible damage to them as a result of natural disasters. Close cooperation with UNESCO would ensure that there are no negative Page 10 of 14 impacts on the cultural value of the sites. The Physical and Cultural Resources framework has been prepared as a measure to mitigate potential significant adverse impacts on Physical Cultural Resources. Public Disclosure Copy The Park Management Plan may include restrictions to the access and use of natural resources within the perimeter of the Park to ensure the biodiversity and environmental sustainability of the Park. The need for such restrictions will be identified in the baseline environmental study and a gender-sensitive social assessment will identify the groups that may be impacted by these restrictions. The Process Framework was developed to ensure that the inclusion of restrictions in the Park Management Plan will be done in participation and in consultation with the affected population and that appropriate mitigation measures for the social impacts of these restrictions are put in place. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area: Component 1 focuses on works that would be done on the Citadel Laferriere, Ramiers, Sans Souci Palace, and other historic sites. These works would primarly focus on structural strengthening to enhance building resilience against disasters, restoration of gardens and archaeological excavations requested by UNESCO. In addition, the component would finance small investments to facilitate access of visiting tourists such as protection railing, public latrines, sanitation facilities. Possible negative impacts include debris and waste management, erosion, worker and public safety and noise. Social impacts may include temporary disruption to vendors who sell outside the historic sites or who transport visitors to the sites. However, every effort would be made to minimize disruption to worker livelihoods. The ESMF, EMP (for the known renovations), RPF and Process Framework have developed screening tools and mitigation measures to ensure that all the possible risks are mitigated. Environmental requirements would also be included in contractor contracts to ensure adherence to worker and public safety and to ensure that mitigation measures are carried out where necessary. Public Disclosure Copy Additional activities would focus on the rural communities bordering the park, particularly Milot and Dondon. The list of possible infrastructure investments in these communities may include some rehabilitation of existing infrastructure (e.g., artisan market, access, water and sanitation). Excluded from this list are are dams and landfills. Since these activities are demand driven, it is not possible to know ahead of time which impacts may be encountered. The use of a screening tool and frameworks will be important during the roll out of these activities. All the frameworks, as well as the screening tools have already been developed. One unintended longer term negative impact of the project may result from an increase of tourism to the sites. An increase in tourists may cause additional people to move into the park, to access the park resources (trees etc) to make handicrafts, and erect temporary structures from which to sell their wares. While this is unlikely to occur within the time frame of our project, it would be important to plan for it. The Government has already put in place some park guards to reduce pressure on the natural habitat surrounding the park as a first step. In addition, through the Project's financing, there would be a business management plan for the park which, although focused on increasing park revenues, would also engage in spatial planning for the park. This would serve to regulate any temporary or illegal structures. The Project team would also discuss with Government the need to put in place longer term planning for protection of the natural habitat in the park beyond park guards (e.g., educational programs on conservation, etc). In the event that these discussions would engender the need to restrict access to natural resources within the Page 11 of 14 perimeters of the park, a Process Framework was developed to ensure that these discussions include the full participation and consultation of the affected groups. As the same time a detailed gender –sensitive social assessment is being carried out as a measure to mitigate potential Public Disclosure Copy significant social impacts. 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. To minimize large scale adverse impacts, some investments were considered and discarded such as dam renovations, landfills and the designation of market areas. These were considered to be too large-scale and with too many possible adverse impacts that could not be mitigated on a small scale development program for communities. Any option that would remove the people from the Park has been discarded to avoid social impacts. 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 MEF’s UTE would be responsible for the implementation of the Project. However, given the number of projects they are already responsible for, another environmental and social specialist will be recruited. The social specialist would have an expertise in cultural heritage and experience with Process Frameworks in addition to involuntary resettlement experience. The specialists would be located in the UTE head office, but would be required to spend a certain percentage of their time in the North. 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. Stakeholder consultation is a very important aspect of this project because the project intervenes in a World Heritage site area that is a national and international treasure. Local populations and the international community (IUCN, UN, NGOs, UNESCO etc.) have been consulted as part of this process. Given the higher risk associated with restoring a national treasure and World Heritage Site, a mechanism would be set up to ensure full two-way communication with all stakeholders. The project would therefore finance a communications and outreach plan that allows for the Public Disclosure Copy monitoring and follow-up of stakeholder feedback. The development of the RPF, Process Framework, ESMF, EMPs and PCRF was also a consultative process. B. Disclosure Requirements Environmental Assessment/Audit/Management Plan/Other Date of receipt by the Bank 05-Dec-2013 Date of submission to InfoShop 17-Dec-2013 For category A projects, date of distributing the Executive Summary of the EA to the Executive Directors "In country" Disclosure Haiti 18-Dec-2013 Comments: Resettlement Action Plan/Framework/Policy Process Date of receipt by the Bank 05-Dec-2013 Date of submission to InfoShop 17-Dec-2013 "In country" Disclosure Haiti 18-Dec-2013 Comments: Page 12 of 14 Pest Management Plan Was the document disclosed prior to appraisal? Yes Date of receipt by the Bank 05-Dec-2013 Public Disclosure Copy Date of submission to InfoShop 17-Dec-2013 "In country" Disclosure Haiti 18-Dec-2013 Comments: If the project triggers the Pest Management and/or Physical Cultural Resources policies, the respective issues are to be addressed and disclosed as part of the Environmental Assessment/ Audit/or EMP. If in-country disclosure of any of the above documents is not expected, please explain why: C. Compliance Monitoring Indicators at the Corporate Level OP/BP/GP 4.01 - Environment Assessment Does the project require a stand-alone EA (including EMP) Yes [ ] No [ ] NA [ ] report? If yes, then did the Regional Environment Unit or Sector Yes [ ] No [ ] NA [ ] Manager (SM) review and approve the EA report? Are the cost and the accountabilities for the EMP incorporated Yes [ ] No [ ] NA [ ] in the credit/loan? OP/BP 4.04 - Natural Habitats Would the project result in any significant conversion or Yes [ ] No [ ] NA [ ] degradation of critical natural habitats? If the project would result in significant conversion or Yes [ ] No [ ] NA [ ] Public Disclosure Copy degradation of other (non-critical) natural habitats, does the project include mitigation measures acceptable to the Bank? OP 4.09 - Pest Management Does the EA adequately address the pest management issues? Yes [ ] No [ ] NA [ ] Is a separate PMP required? Yes [ ] No [ ] NA [ ] If yes, has the PMP been reviewed and approved by a Yes [ ] No [ ] NA [ ] safeguards specialist or SM? Are PMP requirements included in project design?If yes, does the project team include a Pest Management Specialist? OP/BP 4.11 - Physical Cultural Resources Does the EA include adequate measures related to cultural Yes [ ] No [ ] NA [ ] property? Does the credit/loan incorporate mechanisms to mitigate the Yes [ ] No [ ] NA [ ] potential adverse impacts on cultural property? OP/BP 4.12 - Involuntary Resettlement Has a resettlement plan/abbreviated plan/policy framework/ Yes [ ] No [ ] NA [ ] process framework (as appropriate) been prepared? Page 13 of 14 If yes, then did the Regional unit responsible for safeguards or Yes [ ] No [ ] NA [ ] Sector Manager review the plan? Public Disclosure Copy OP/BP 4.36 - Forests Has the sector-wide analysis of policy and institutional issues Yes [ ] No [ ] NA [ ] and constraints been carried out? Does the project design include satisfactory measures to Yes [ ] No [ ] NA [ ] overcome these constraints? Does the project finance commercial harvesting, and if so, Yes [ ] No [ ] NA [ ] does it include provisions for certification system? 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 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? Public Disclosure Copy 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: Name: Sylvie Debomy Approved By Regional Safeguards Name: Glenn S. Morgan (RSA) Date: 09-Jan-2014 Advisor: Sector Manager: Name: Anna Wellenstein (SM) Date: 15-Jan-2014 Page 14 of 14