INTEGRATED SAFEGUARDS DATA SHEET ADDITIONAL FINANCING Report No.: ISDSA8219 Date ISDS Prepared/Updated: 14-Apr-2014 Date ISDS Approved/Disclosed: 16-Apr-2014 I. BASIC INFORMATION 1. Basic Project Data Country: Haiti Project ID: P149116 Parent P106699 Project ID: Project Name: Haiti - Urban Community Driven Development Project - AF (P149116) Parent Project Haiti - Urban Community Driven Development Project / PRODEPUR (P106699) Name: Task Team Ali Alwahti Leader: Estimated 15-Apr-2014 Estimated 19-Jun-2014 Appraisal Date: Board Date: Managing Unit: LCSDU Lending Investment Project Financing Instrument: Sector(s): General water, sanitation and flood protection sector (40%), Other social services (25%), General public administration sector (15%) , Urban Transport (10%), General education sector (10%) Theme(s): Participation and civic engagement (40%), Urban services and housing for the poor (40%), City-wide Infrastructure and Service Delive ry (20%) 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) Total Project Cost: 6.00 Total Bank Financing: 6.00 Financing Gap: 0.00 Financing Source Amount BORROWER/RECIPIENT 0.00 IDA Grant 6.00 Total 6.00 Environmental B - Partial Assessment Category: Is this a No Repeater project? Page 1 of 13 2. Project Development Objective(s) A. Original Project Development Objectives – Parent To improve access to (and satisfaction with): a) basic and social infrastructure and services; and b) income generatingopportunities for residents of targeted disadvantaged urban areas. This objective will be achieved through a participatory processin which community-based organizations propose, select, implement, and maintain subprojects. B. Current Project Development Objectives – Parent To improve access to, and satisfaction with: (i) basic and social infrastructure and services, including housing repair, reconstruction and community infrastructure improvements needed as a result of the emergency; and (ii) income-generating opportunities for residents of targeted disadvantaged urban areas. C. Proposed Project Development Objectives – Additional Financing (AF) 3. Project Description The Parent Project was designed as a Community Driven Development operation with most funding earmarked for community sub-projects and emergency response and reconstruction activities following the earthquake. All components are implemented through a participatory process in which Community-Driven Project Development Councils (COPRODEPs) were created to propose, select, implement and maintain investment sub-projects implemented jointly with Community Based Organizations (CBOs). The Project provides financing for community sub-projects focused on basic municipal infrastructure, housing and reconstruction, social infrastructure, and productive/income generating opportunities. The Project consists of four Components: a. Component 1 finances community demand-driven and municipal sub-projects in 14 targeted Priority Zones of 6 municipalities. Specific results include: (i) the establishment of 14 Community Councils (COPRODEP) in targeted areas of Port-au-Prince and three other cities; and (ii) the financing of 493 sub-projects (467 sub-projects were originally planned). This Component has fully disbursed; b. Component 2 finances technical assistance such as training-of-trainers, capacity building, technical workshops, and consultant services aimed at strengthening governance, participatory development, supervision, and coordination of project beneficiaries and stakeholders. This Component has disbursed less than one-third of the originally projected funds; c. Component 3 finances incremental costs associated with the project’s implementation, administration, supervision, monitoring and evaluation. This Component has fully disbursed; d. Component 4 finances housing and community recovery and reconstruction activities, specifically debris removal, housing repair and reconstruction through cash grants, infrastructure improvement, as well as advisory services, international and local technical assistance to support urban development and housing strategies. Several significant activities were completed over the last 6 months, particularly regarding infrastructure improvement. These include: (i) rehabilitation of more than 50 street corridors; (ii) repair or reconstruction of 1,200 houses, allowing about 1,740 families to return to safe neighborhoods with safe housing options, or to receive a rental subsidy; (iii) completion of the design of a multi-family complex; (iv) completion of technical designs of key roads to be rehabilitated; and (v) commencement of works for the first large road. As a result of Page 2 of 13 investments under this Component, approximately 24,800 households are benefiting from community-wide upgrading, including basic infrastructure and services. Seventy-four (74) percent of the funds under this component are committed and 56 percent disbursed. 4. Project location and salient physical characteristics relevant to the safeguard analysis (if known) The Parent Project intervened in disadvantaged urban areas, such as Cité-Soleil, Port-au-Prince, Cap- Haitien, Gonaives, St. Marc under Components 1 and 2, while under Component 4, the Parent Project intervened in informal neighborhoods in the Port-au-Prince area severely affected by the earthquake. . These targeted disadvantaged urban areas are traditional flash-point communities and were seriously damaged by the January 12, 2010 earthquake. Under the proposed Additional Financing, the geographic scope of subproject activities would be extended to include secondary cities in the North, Center and Artibonite Departments considering: (i) the importance of secondary cities for poverty reduction and balanced economic development in the country; and (ii) the need for synergy with two upcoming Bank projects, whose areas of intervention overlap with that of the proposed operation: Cultural Heritage Preservation and Tourism Sector Development Support Project (P144614) (North and Nord-East departments), and Center and Artibonite Regional Development Project (P133352), both FY2014. Specifically, the proposed AF would expand to include Dondon, Milot, Hinche and Mirebalais. 5. Environmental and Social Safeguards Specialists Amadou Konare (AFTN1) Peter F. B. A. Lafere (LCSSO) 6. Safeguard Policies Triggered? Explanation (Optional) 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 project's main components. Due to demand-driven nature of and the lack of specifics on the sub-projects’ sites and scale at this time, a framework approach, as in the parent project, has been proposed, whereby the government would prepare and Environmental and Social Management Framework (ESMF). The proposed PRODEPUR AF will scale up PRODEPUR’s activities. The type of activities to be financed would be the same as those currently included in the project. Therefore, the project category under PRODEPUR AF remains unchanged as B. The existing parent project’s ESMF has been updated to reflect the environmental and social characteristics of the new project intervention areas. The ESMF provides clear guidance and measures, Page 3 of 13 with the associated implementation arrangements, with clear roles and responsibilities, along with capacity strengthening measures for effective implementation and monitoring of the ESMF. It also provides cost outlays and a timetable for preventing and mitigating potential impacts. In particular, the ESMF provides steps for screening all subprojects, outlines procedures for preparing, reviewing, clearing, disclosing and monitoring subproject-specific ESIAs/ESMPs. As a condition of investment, it has been agreed that no civil works will commence, without proper compliance with the above procedures. A separate, additional Social Assessment will not be undertaken for the proposed AF, given the experience of BMPAD in the areas of project implementation. Both the Cultural Heritage Preservation and Tourism Sector Support Project (P144614) (for Milot and Dondon) and the Center and Artibonite Regional Development Project (P133352) (for Mirebalais and Hinche) are undertaking Social Assessments in these areas. The findings of these assessments will be shared with BMPAD. Natural Habitats OP/BP 4.04 Yes The Natural Habitats (OP/BP 4.04) policy is triggered because the area around the National Historic Park (Parc National Historique) is known to be one of the few remaining natural 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. This suggests that the Bank will not finance any subproject or activity with potential adverse impacts on this type of natural habitats, according to OP/BP 4.04 policy and guidelines. This has implications for the cities of Dondon and Milot, which are situated within and on the perimeter of the National History Park. The ESMF has been updated to screen out activities that may negatively impact the site, and details criteria for Page 4 of 13 identifying and managing all other social and environmental impacts to the site, including any indirect impact associated with project’s investments. For project intervention in the Northern part of country, a three-prong screening procedure has been devised: (i) All investments will be screened by the MDODs; (ii) the resulting screening forms will be reviewed and either revised or validated by BMPAD in conjunction with the Institut de Sauvegarde du Patrimoine National (ISPAN), in accordance with the presidential decree of 21 June 2010 that establishes the National Historic Park and ISPANs authority thereover; and (iii) the Bank, through the safeguards specialists on the project, would be provided with the list of sub- projects or activities selected for investment for their concurrence. During supervision missions, the safeguards specialists on the Team will purposely assess compliance with required safeguards for sub-projects in Dondon and Milot. Forests OP/BP 4.36 Yes The Forests (OP/BP 4.36) policy is triggered because evidence from the existing baseline information, suggests poor management practices of the park in general and minimal safeguards for forest products, in particular. Without proper activity/sub-project screening, selection, validation procedures, and the implementation of required safeguards, the PNH and its forest could further be negatively impacted by project’s activities. Screening for potentially negative impacts on forests will be done in-tandem with potential impacts on natural habitats, using the same three-prong screening approach described under OP/BP 4.04 above. Pest Management OP 4.09 No None of the proposed AF’s components triggers the Pest Management Policy. Physical Cultural Resources OP/ Yes The Physical Cultural Resources (OP/BP 4.11) BP 4.11 policy was triggered in the original project in the event that the civil works might directly and/or indirectly affect cultural property in existing neighborhoods, such a known local structures or sites of historic or cultural importance. The highly participatory nature of the project coupled with the screening procedures outlined in the ESMF ensures that communities would be able to Page 5 of 13 identify if any proposed sub-project will have an impact on cultural property as defined by the policy. Sub-project proposals require the identification of any such activities and require the CBO proposing the sub-project to specify adequate mitigation measures. This process is captured in the ESMF, which also includes guidance on preparing chance find clauses for contractors in bidding documents for any construction activities supported by the project Two of the sites that will be financed under the AF, Milot and Dondon, are situated within and on the perimeter of the National History Park, a UNESCO World Heritage Site. The ESMF has been updated to screen out activities that may negatively impact the site. In addition, dispositions taken for subsequent sub- project-specific safeguards instruments will entail ensuring that ESIAs/ESMPs consultants and contractors are able to do the due diligence, or are teamed up with Physical Cultural Resources (PCR) experts to ensure that impacts on PCR are assessed and mitigation measures commensurate to those impacts, including proper handling of chance finds are implemented in the design, in accordance with national and World Bank policies. The Project team and implementers shall ensure that the proposed mitigation measures are derived from Projects and subproject specific ESIAs/ ESMPs, and more specifically: (i) have been discussed and agreed upon by concerned parties; (ii) include an assessment of the capacity to implement the measures; and (iii) are acceptable within the national regulatory and legal framework, including laws and regulations concerning cultural heritage and the antiquities. These processes and other dispositions related to PCR are discussed in the ESMF, which also includes guidance on preparing chance find clauses for contractors in bidding documents for any construction activities supported by the Page 6 of 13 project. A separate Physical and Cultural Resources Framework (PCRF) that was prepared and disclosed for the Cultural Heritage Preservation and Tourism Sector Support Project (P144614) will be re-disclosed, as part of PRODEPUR AF’s safeguard documents. The PCRF provides appropriate guidance for project implementation in a PCR-rich area. All sub-projects within the perimeter of the Natural Historic Park will require prior authorization by the Institut de Sauvegarde du Patrimoine National (ISPAN) in accordance with the presidential decree of 21 June 2010 that establishes the National Historic Park and ISPANs authority thereover. Indigenous Peoples OP/BP 4.10 No There are no indigenous peoples as defined by the policy present in the project areas. Involuntary Resettlement OP/BP Yes The planned activities under the proposed AF are 4.12 not expected to result in land acquisition or involuntary resettlement. Community subprojects under Component 1 will screen out activities that would require resettlement or that would result in restriction of access to natural resources in protected areas, and the sub-grants for emergency reconstruction will finance settlement (housing and community infrastructure) rehabilitation and reconstruction in-situ. To allow flexibility to respond to emergencies or changing priorities, OP 4.12 will continue to be triggered in the AF. In the event that minor involuntary resettlement would be required, a Resettlement Action Plan will be prepared in accordance with the OP 4.12 along the same principles of the original Resettlement Policy Framework, as well as from the lessons learnt from the RAPs that were developed and implemented in the original project for urban upgrading activities. The RPF has been updated to include the new project areas and re-disclosed. A formal ex-post evaluation of those RAPs will be carried out by 30th June 2014. This policy reflects the following principles: # Prior to the approval of eligible beneficiaries, BMPAD with the assistance of the MDOD and the relevant COPRODEP need to ensure that the sites, boundaries and ownerships of the land plots need to be clearly identified, Page 7 of 13 reconfirmed by their neighbors and verified by the housing facilitators (the community-based mapping exercise). # In cases where there are disputed claims, conflict resolution will be facilitated by BMPAD and the MDOD community outreach workders through the conflict resolution mechanism in the Community Reconstruction Center. # In case there is resettlement, agreement on the compensation scheme and its payment or realization will be settled prior to the commencement of that particular housing rehabilitation or reconstruction. Safety of Dams OP/BP 4.37 No The policy is not triggered since project will not invest in dams nor will 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 will not affect any known International Waterways. Projects in Disputed Areas OP/BP No The policy is not triggered since project activities 7.60 will not affect any known disputed areas. II. Key Safeguard Policy Issues and Their Management A. Summary of Key Safeguard Issues 1. Describe any safeguard issues and impacts associated with the proposed project. Identify and describe any potential large scale, significant and/or irreversible impacts: As in the Parent Project, there are no potential large scale, significant and/or irreversible social negative impacts expected. The key social issues relate to Component 4 and include: (a) the accurate identification of families that lived in each house in the project intervention area prior to the Emergency, (b) determining their property tenure status, (c) developing assistance options that adequately address the situation of all categories of affected families/houses, especially renters and sub-renters (d) addressing the needs of vulnerable groups, (e) possible discovery of human remains during the process of debris removal, and (f) addressing temporary physical relocation that may be necessary as a result of house repair or reconstruction. In order to address the above issues adequately, the program will: (a) continue to rely on community-based processes to identify and address issues, (b) continue consultations with the community throughout program preparation and implementation based on dissemination of prior relevant information, (c) develop clear entitlement criteria and assistance options for all categories of affected families, especially renters and sub-renters, (d) promote special measures to address the needs of vulnerable groups, (e) put in place an agreed, community-endorsed protocol to deal with possible discovery of human remains during debris removal, (f) when required, develop an adequate resettlement plan to address possible relocation of beneficiaries in the realization of public works, (g) carry out community-based mapping prior to ascertain property tenure status of beneficiaries; and (h) establish a durable conflict resolution mechanism to address any complaints, disputes or grievances that beneficiaries may have during the design and implementation of the Page 8 of 13 program. The conflict resolution mechanism will be housed in the Community Reconstruction Center and will be available to resolve conflicts arising from any component or activity supported by PRODEPUR. In addition, close coordination and consultation of key stakeholders will contribute to identifying any additional, critical social issues, and to solicit suggestions on how to best address them. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area: Based on the ongoing experience with sub-projects to date, long-term impacts are expected to be positive. The project is likely to result in significant improvements in building social capital, infrastructure and capacity in target areas. While Martissant and Cite Soleil were selected using standard eligibility criteria on (i) poverty level; (ii) population density; and (iii) current and past levels of violence and target the most disadvantaged populations, Mirebalais, Hinche, Milot and Dondon were selected to complement large scale infrastructure investments under other Bank financed operations in order to enhance social inclusion and community capacity. Moreover, through environmental management activities and related technical assistance, it is expected to result in significant environmental improvements. 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. An assessment of safeguards implementation, in compliance with applicable Bank operational policies, has shown gradual improvement, based on the sustained training of the various stakeholders (i.e., MDODs, CBOs, COPRODEPs and contractors) involved in the project’s safeguards function over the past several months. Other streamlining procedures, such as the designation of safeguards Focal Point in each MDODs, reinforcing a reporting culture in both BMPAD and the MDODs, have but proven to be effective measures in mainstreaming safeguard considerations in project’s implementation. Alternatives to the technical and institutional measures discussed above would be considered unsustainable for any development effort that seeks to be environmentally and socially friendly. 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. As the national executing agency of the project on behalf of the Government of Haiti (GoH), BMPAD has been responsible for overall project coordination and oversight of the Parent Project, the first additional finance and will continue to be responsible for the proposed AF. BMPAD will also continue to delegate day-to-day project execution to the MDODs. BMPAD will nonetheless continue to provide continuous oversight of (i) the environment and social impact screening process; (ii) the sourcing of materials to ensure that national policies and environment best practice are followed; (iii) the implementation of investment-specific mitigation measures; and (iv) the execution of information campaigns and consultations. BMPAD will also continue to provide training to the MDODs, COPRODEPs and CBOs on environment and social impact assessment and impact management. To date, BMPAD has provided more than a dozen and a half safeguards trainings to the MDODs, CBOs and COPRODEPs under PRODEPUR and PRODEP (the related rural CDD project). These trainings have consisted of training-of-trainer events in (a) basic management, administration, accounting, safeguards and financial management for COPRODEPs and municipal government officials; (b) capacity building and technical assistance to strengthen governance, participatory development, supervision, and coordination capacity at the municipal-government level and to relevant ministerial staff; (c) workshops with service providers to harmonize social and Page 9 of 13 environment practices to assist CBOs and COPRODEPs in carrying out project activities; (d) training of Bureau de Monétisation staff to effectively supervise the identification and management of environment and social impacts and their associated mitigation measures. To mainstream environmental and social safeguard considerations in project’s implementation, monitoring and supervision and to further enhance compliance with applicable safeguard policies, each of the MDODs has designated a Focal Point (FP) for safeguards, following the Project’s Mid- Term Review (MTR). The objective of this disposition was to ensure that guidance and oversight is provided at all time on safeguards within each MDOD. These safeguards FPs and contractors have undergone several training sessions on Bank safeguard policies, sub-project screening process, selection, implementation and monitoring and other safeguards enhancement measures, such as reporting, in the months that followed the MTR. These and other dispositions have proven to be very effective in improving safeguards performance. With this operation, the Project is not only building on many years of experience implementing Bank-funded projects, but also on lessons learned from implementation of those operations. This provides the Project Team and relevant actors a good framework for smooth implementation of safeguards measures. The safeguard instruments include further provisions for capacity strengthening at all levels for the successful implementation of the project safeguard measures, in compliance with national and World Bank safeguard policies. Moreover, as the project is set out to intervene in the Northern part of country, an area of global importance, both from its biodiversity and physical cultural resources standpoints, a three-prong screening procedure has been devised: (i) all investments will be screened by the MDODs; (ii) the resulting screening forms will be reviewed and either revised or validated by BMPAD in conjunction with the Institut de Sauvegarde du Patrimoine National (ISPAN), in accordance with the presidential decree of 21 June 2010 that establishes the National Historic Park and ISPANs authority thereover; and (iii) the Bank, through, the safeguards specialists on the project would be provided with the list of sub-projects or activities selected for investment for their concurrence. As such, BMPAD has exhibited sufficient capacity to und ertake safeguards implementation under the parent project and the first additional finance. Application of safeguards in the context of the proposed operation is bound to further improve, in light of sustained efforts by the MDODs, BMPAD and the Bank Team to streamline safeguards implementation, monitoring and oversight arrangements over the many months following the MTR. BMPAD’s comprehensive Operational Manual (Manuel d’Opération, or OM) includes relevant provisions gleaned from the ESMF of the parent project. The OM has since been updated twice: with the first additional finance and more recently with the proposed additional finance. The provisions of the OM concerning safeguards have thus far been satisfactorily applied. Support will also be provided by World Bank supervision teams. The supervision missions will always include the environmental and social safeguards specialists on the team. To ensure effective World Bank supervision, BMPAD will prepare and update detailed reports on the implementation of activity/sub-project-specific EMP and/or RAP, whichever is applicable, before World Bank supervision missions. During supervision missions, the safeguards specialists on the Team will purposely assess compliance with the sub-projects’ safeguards in Dondon and Milot. Appropriate budget for supervision will be included in the Project financial evaluation. Page 10 of 13 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. The key stakeholders include communities, mayors and other communal representatives, NGOs (MDODs), and related government agencies. The preparation and update of the safeguard documents (i.e., ESMF, RPF and subsequent sub-project-specific instruments), under the parent and first additional finance, followed a broad-based and in-depth consultative approach that included interviews with relevant project stakeholder groups. The Communication and Dissemination campaigns devised under both the parent project and the first additional finance have particularly proven to be successful in engaging and develop stakeholder interests and ownership in projects’ design, implementation and outcomes. BMPAD and the MDODs, have worked through the COPRODEPs to consult with local communities regarding the proposed project activities, potential adverse impacts, proposed safeguard instruments. In addition, a communication strategy was developed that has shown to be effective in promoting a genuine, community-led process that was perceived as fair and meaningful by all stakeholders. This included consulting on project timelines, eligibility criteria, and assistance packages. The disclosed projects documents were readily available to stakeholder and interest groups in the country Disclosure of the projects. It is expected that same consultative approach and processes will be followed in the context of the revision of the updated ESMF, following the Bank’s comments. The updated ESMF will be disclosed to affected peoples, other stakeholders and interest groups, both locally and through the InfoShop, upon completion. B. Disclosure Requirements Environmental Assessment/Audit/Management Plan/Other Date of receipt by the Bank 11-Apr-2014 Date of submission to InfoShop 11-Apr-2014 For category A projects, date of distributing the Executive Summary of the EA to the Executive Directors "In country" Disclosure Haiti 08-Apr-2014 Comments: Resettlement Action Plan/Framework/Policy Process Date of receipt by the Bank 14-Apr-2014 Date of submission to InfoShop 14-Apr-2014 "In country" Disclosure Haiti 14-Apr-2014 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: Page 11 of 13 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 [ ] degradation of other (non-critical) natural habitats, does the project include mitigation measures acceptable to the Bank? 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? If yes, then did the Regional unit responsible for safeguards or Yes [ ] No [ ] NA [ ] Sector Manager review the plan? 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? Page 12 of 13 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: Name: Ali Alwahti Approved By Regional Safeguards Name: Glenn S. Morgan (RSA) Date: 16-Apr-2014 Advisor: Sector Manager: Name: Catalina Marulanda (SM) Date: 16-Apr-2014 Page 13 of 13