INTEGRATED SAFEGUARDS DATA SHEET APPRAISAL STAGE Report No.: ISDSA6808 Public Disclosure Copy Date ISDS Prepared/Updated: 26-Nov-2013 Date ISDS Approved/Disclosed: 16-Sep-2013, 28-Nov-2013 I. BASIC INFORMATION 1. Basic Project Data Country: Vietnam Project ID: P128072 Project Name: VN - Central Highlands Poverty Reduction Project (CHPov) (P128072) Task Team Sean Bradley Leader: Estimated 17-Sep-2013 Estimated 27-Dec-2013 Appraisal Date: Board Date: Managing Unit: EASVS Lending Specific Investment Loan Instrument: Sector(s): General agriculture, fishing and forestry sector (40%), Other social services (30%), Sub-national government administration (20%), P ublic administration- Other social services (10%) Theme(s): Rural services and infrastructure (40%), Other human development (30%), Participation and civic engagement (30%) 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: 159.40 Total Bank Financing: 150.00 Financing Gap: 0.00 Financing Source Amount BORROWER/RECIPIENT 9.40 International Development Association (IDA) 150.00 Total 159.40 Environmental B - Partial Assessment Category: Is this a No Repeater project? 2. Project Development Objective(s) The proposed project development objective of the Central Highlands Poverty Reduction project is to: enhance living standards by improving livelihood opportunities in Project Communes of upland Districts of the central highlands of Vietnam. Page 1 of 12 3. Project Description The project will target the 26 poorest districts in six provinces of the Central and Central Highlands regions, namely: Dak Lak, Dak Nong, Kon Tum, Gia Lai, Quang Nam and Quang Ngai. Current Public Disclosure Copy targeting strategies propose to reach approximately 119,492 households in the poorest 130 communes in this area. A majority of these beneficiaries would be members of the various ethnic minority groups from these areas. The project will have four components: village and commune infrastructure development, sustainable livelihoods development, connective infrastructure development and strengthening of linkages, and project management. Component 1: Village and Commune infrastructure development (consisting of two sub-components and estimated to cost US$ 54.8 million, of which US$ 52.4 million would be financed by IDA). Sub- component 1.1 would support the design, construction or repair of small-scale village and commune- level infrastructure (such as simple access roads, terracing; irrigation/water supply, basic social infrastructure, etc.). Building upon recently completed New Rural Areas communal plans, sub- projects would be prioritized through a participatory planning process and managed by commune and village authorities with the help of community facilitators. Depending on the size and complexity of the identified sub-project investments, community groups would take direct responsibility for managing construction of infrastructure (for sub-projects valued at less than VND 300 million, or US $ 15,000).) This participatory process is modeled on community-driven development (CDD) approaches used effectively throughout the world and successfully adapted under local projects such as the Northern Mountains Poverty Reduction Project (1 and 2) and the Program 135, both of which have received support from the World Bank. Sub-component 1.2 would finance sub-projects for the operation and maintenance (O&M) of communal infrastructure. Such sub-projects could include routine maintenance and small repair activities for both existing and new investments (which have been financed by the project). The O&M would contribute to the sustainable use of invested infrastructure and ensure lasting impacts on improving access and connectivity in the project areas. Public Disclosure Copy Component 2: Sustainable Livelihoods Development (consisting of two subcomponents and estimated to cost US$ 35.2 million, of which US$ 35.2 million would be financed by IDA). Component 2 would support EMs and other households in the targeted areas to enhance their food security and nutrition, their productive capacities for more diversified income sources, and their linkages to selected agricultural markets. Sub-component 2.1 (“Self-reliance and Income Generation”) would target chronically poor and at risk households and include activities to: (a) strengthen household and community food security and nutrition (via improved practices for staple food crops and small livestock-raising, soil management on sloped land, home garden development, nutrition awareness etc.); and (b) sustain/diversify income sources by enhancing the productive capacities of beneficiaries. Sub-component 2.2 (“Market Linkage Initiatives”) will aim to develop productive partnerships (PP) between farmer groups and agribusinesses (ABs) operating in the targeted areas for proven commercially viable agriculture/agro-forestry endeavors. The Department of Agriculture and Rural Development (DARD), the National Targeted Program for Nutrition (NTP- NU) and the Women’s Union (WU) would play key roles in advising on and supporting implementation of sub-component 2.1, and DARD and the private and commercial sector would be engaged as appropriate under sub-component 2.2. Support and assistance would be provided through “livelihoods enhancement groups” (LEGs) that would be registered legal entities and would consist of 10-20 member households, depending on the nature of the livelihood activity. The component would include the financing of a specialized technical assistance team to support, in particular, sub- Page 2 of 12 component 2.2. Component 3: Connective infrastructure development, capacity building and communications Public Disclosure Copy (consisting of three sub-components and estimated to cost US$ 53.0 million, of which US$ 51.4 million is financed by IDA). Sub-component 3.1 would finance selective intra- and inter-commune level infrastructure that would strengthen physical connectivity seek within and between local economic zones (such as roads, bridges, irrigation systems, etc.). Due to the likely size and costs of these investments, District-level entities would manage their implementation. However, their identification and prioritization would happen as a result of the commune-level analysis and sub- project planning process. The component would prioritize investments that enhance synergies with Component 1 and/or 2 investments. While initially emphasizing productive connectivity, investments in other infrastructure (or services) deemed to be critical to expanding the networks or linkages EMs may have with areas outside their communes (such as secondary school residential facilities) could be considered. Sub-component 3.2 would support training and capacity building at all project levels for all aspects of project management (planning, financial management, procurement, monitoring and evaluation, etc.). The sub-component would include the financing of a technical assistance team (TAT) consisting of international and national specialists in project management, livelihoods and agricultural market linkages, capacity building, M&E, etc. A summary description of the TAT is presented in Annex 3. Sub-component 3.3 would support communications activities to ensure beneficiaries, project staff, key stakeholders and the public at large were aware of the project objectives and operational principles. These activities would pay special attention to communication and outreach activities to EM beneficiaries where it will be important to adapt the form and language of messages to local contexts and abilities.. An estimated one-third of the total budget under component 3 would be dedicated to sub-components 3.2 and 3.3. Component 4: Project management (estimated US$ 16.5 million, of which US$ 11.0 million would be financed by IDA). Sub-component 4.1, project coordination and implementation, would include Public Disclosure Copy the set-up and operation of coordination structures at national level and implementation units/teams at provincial, district and commune levels, and operational costs associated with project management. At commune level existing structures would be strengthened to support project implementation. Sub-component 4.2, monitoring and evaluation, would include the design and implementation of a simple management information system (MIS) for project monitoring, the design and contracting of a rigorous impact evaluation, the recruitment of key personnel at central, provincial and district level to support M&E activities, and would support various knowledge exchange and learning activities between participating provinces, with other similar projects in Vietnam and within the region. This would also include the set-up and maintenance of a project website to disseminate key project documents and reports, and to provide regular updates on project activities and progress. 4. Project location and salient physical characteristics relevant to the safeguard analysis (if known) The Project covers 6 project provinces of Dak Lak, Dak Nong, Gia Lai, Kon Tum, Quang Ngai and Quang Nam. Quang Ngai and Quang Nam are coastal provinces but project districts are located in mountainous areas. The Project area consists of several adjacent highlands, up to 500-1500m above the sea level, such as Kon Tum, Kon Plong, Kon Ha Nung, Pleiku, M’Drak, Buon Ma Thuot, Mo Long, Lam Vien and Di Linh. All of these highlands are adjacent to the Nam Truong Son mountain range to the east. Located in the tropical savannah, the climate in the Central Highlands is divided Page 3 of 12 into two seasons: the rainy season from May to October and the dry season from November to April, in which March and April are the hottest and driest months of the year. The climate characteristics play an important role in the selection of livelihood in the Project area. Notably, while the Central Public Disclosure Copy Highlands is famous for its potential of high-value industrial crops (such as coffee, pepper, rubber and cashew), the Project districts basically are not located in the area of favorable weather condition and land for such potential development, compared with other districts. Quang Nam and Quang Ngai provinces are coastal provinces and on the northern side of the project area (and not formally part of the Central Highlands region). Quang Nam belongs to the key economic development zone of Central Vietnam and has a relatively complex terrain, with mountainous area accounting for 72% of the total natural area. However, the three project districts (Nam Giang, Phuoc Son and Nam Tra My) are amongst the poorest in the provinces (as well as in the country).Quang Ngai Province borders the east of Central Highlands with a relatively complex terrain. The total natural area is 5,152.7 km2 with the coast spanning 129 km. Similar to the Central Highlands, the climate in Quang Nam and Quang Ngai consists of two distinct seasons, rainy and dry. However, the provinces are also under the influence of the North’s cold winter season. Rainfall is heavier in the mountains than in the plains and 80% of the annual rainfall falls from September to December. As the rainy season coincides with the typhoon season, heavy rains in the Central Vietnam usually cause landslides and flash floods in midland districts and flooding in the riverside areas. The majority of land in the Project area for all 6 provinces is forested. The Project districts of Dak Nong have the lowest proportion of the forest land at only 50% of total, while the highest proportion is 77% in Kon Tum. However, most of the forest land belongs to the protection forest area, special- purpose forest and nature reserve area. Productive forest land only accounts for a small proportion (approximately 18% of the total forest land) and belongs to many state-owned companies. The fact that parts of the forest land is rocky soil and emaciated soil also make it difficult to cultivate. Thus, the proportion of productive forest land that is in possession of individual households is quite low (no official data available). Total area of agricultural land fluctuates heavily among the provinces; in Dak Public Disclosure Copy Nong it accounts for 42% while in Quang Nam only 4%. 5. Environmental and Social Safeguards Specialists Nghi Quy Nguyen (EASVS) Khang Van Pham (EASVS) 6. Safeguard Policies Triggered? Explanation (Optional) Environmental Assessment OP/ Yes The CHPRP will finance small scale and widely BP 4.01 dispersed productive and social infrastructure (commune-to-village roads, bridges, local irrigation, water supply, schools, markets, etc). The most likely impacts would be during the construction phase, with some possible impacts during operation, both at marginal levels though (e.g. air pollution, waste water and solid waste management). Natural Habitats OP/BP 4.04 No The project is not expected to significantly impact natural habitats given the nature and scale Page 4 of 12 of subprojects. Nevertheless as a precautionary measure, the ESMF includes provision for screening impacts on natural habitats. Subprojects Public Disclosure Copy that significantly degrade or convert natural habitats will be avoided. Forests OP/BP 4.36 Yes Approximately 50 percent of the project area is forests or forest lands and analysis of rural livelihoods in the project area indicates that access to forest resources (including non-timber forest products) is an important strategy for poor ethnic minority households. Potential livelihood activities (under component 2) that would require consideration of this policy include tree crops (acacia, litsea or cacao) or other agriculture activities to be undertaken on production forest lands. Pest Management OP 4.09 Yes OP 4.09 on Pest Management has been triggered since potential investments in irrigation infrastructure under components 1 and 3, and proposed agricultural livelihood models under component 2, may directly involve (or indirectly lead to) an increased use of fertilizers and pesticides. Physical Cultural Resources OP/ No The project would not involve significant BP 4.11 excavations, demolition, movement of earth, flooding, or other environmental changes. It would not be located in, or in the vicinity of, Public Disclosure Copy physical cultural resources site recognized by the borrower. Nevertheless the ESMF includes Chance Find Procedures in case PCRs are discovered during subproject implementation. Indigenous Peoples OP/BP 4.10 Yes The project area includes more than 41 different EM groups, including groups indigenous to the region and groups from other areas of the country. A significant majority (more than 72 percent) of project beneficiaries will be members of these groups. Involuntary Resettlement OP/BP Yes Small scale village, commune and district 4.12 infrastructure may require the acquisition of residential or productive land, or compensation for lost (principally agricultural) assets, at marginal levels though. Given the demand-driven nature of the project's activities, voluntary land donation may also be used for sub-projects. Safety of Dams OP/BP 4.37 No The Project involves no construction of dams nor are the project activities dependent vulnerable Page 5 of 12 in any way to any existing upstream dam or dam under construction. Projects on International No No Project activities are to be carried out on an Public Disclosure Copy Waterways OP/BP 7.50 international waterway. Projects in Disputed Areas OP/BP No No part of the Project activities are in a disputed 7.60 area so the policy is not triggered. 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: The potential impact of any sub-project will depend on the nature, location and specific characteristics of the sub-project investment. Based on experiences with similar projects in Vietnam, in most cases the environmental impacts of such sub-projects are expected to be minor, temporary, site-specific and reversible, and limited to the construction phase. The negative impacts during construction include increased noise, dust, waste, or run-off; damage/loss of vegetation; and safety or health risks relating to construction activities. During operation, an increase in irrigated land may lead to an increase in the use of fertilizers and pesticides that may cause pollution to soil, water and air. In addition, works to irrigation and drainage systems may lead to agricultural production interruption due to cutting off of water flow for repair. Investments under component 2, livelihoods support, may also involve the expanded use of pesticides and fertilizers and resulting impacts of pollution to soil, water or air, or negative health impacts associated with the handling of these agro-chemicals. Forest related activities (on production forest land or relating to tree-crops) will generally have a neutral or positive effect (except in relation to increased use of agro-chemicals already mentioned) due to the likely minimal and dispersed nature of the activities and the potential reforestation benefits of tree-crops. Public Disclosure Copy The region is generally characterized by a diverse ethnic population. Overall, in the 26 project districts there are 41 ethnic groups, with ethnic minorities (EMs) accounting for 60.4% of the population, and Kinh group 39.6%. In the 120 project communes, EMs constitute 72.2% of total population, some of whom have immigrated to the Central Highlands region from other areas of the country (primarily the north). Generally, the SA found low rates of participation of community members, especially vulnerable groups (e.g. ethnic minority, women), in the planning, implementation and monitoring of local socio-economic development. Besides low education level and a generally passive attitude toward Government development efforts, limited understanding of Vietnamese will constitute important barriers to ensure full participation and equitable access to project benefits. Based on initial assessments of preliminarily proposed subproject activities, some land acquisition and/or compensation for other assets may be required for commune and village infrastructure in component 1 and 3. The extent of such compensation is expected to be minor, however, as all investments identified to date (for the first 18 months of project implementation) are for the repair or upgrading of existing infrastructure. Provinces are currently surveying the preliminary subproject lists and will confirm to MPI and the World Bank if any land acquisition would be required and how this would be addressed (either thru compensation or identification of an alternative investment). Page 6 of 12 The project is not expected to have any large-scale or irreversible impacts. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities Public Disclosure Copy in the project area: Given the nature and small-scale size of the project investment activities, combined with the application of the safeguard measures discussed below, the long-term direct and indirect environmental and social impacts are generally considered to be positive or neutral. In the case of irrigation investments, however, there some concern of future negative impacts relating to possible increased use of pesticides and fertilizers. While these investments are likely to be relatively small and dispersed, the project will seek to further minimize the use and impacts of such agricultural inputs. In addition to technical training in the use and handling of agro-chemicals, households benefiting from irrigation will also be trained in integrated pest management techniques. 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. Given that project impacts are felt to be overwhelmingly positive, and when negative are generally minimal, dispersed and temporary in nature, alternatives considered (such as not allowing tree- crops or agricultural activities on production forest lands, investing only in upgrading existing infrastructure to avoid issues of land acquisition) were rejected given (i) the importance of certain activities to the livelihoods of the beneficiary groups, and (ii) the allocative efficiencies of ensuring the full demand driven nature of the project. In addition, as per CDD project modalities, the Project Implementation Manual will include a "negative list" of sub-project activities and expenses that will not be eligible for financing under the project based upon compliance with Bank safeguard policies and other project-specific criteria. 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. Based on the Bank’s review through to appraisal, the Project is classified as Category B and triggers three environmental safeguard policies: Environmental Assessment (OP/BP 4.01), Forests Public Disclosure Copy (OP/BP 4.36) and Pest Management (OP 4.09), and two social safeguard policies: Indigenous Peoples (OP/BP 4.10) and Involuntary Resettlement (OP/BP 4.12). Given the demand-driven nature of most of the project’s investments, the requirement for Environmental Assessment will be addressed through the use of an Environmental and Social Management Framework (ESMF) document. This document has been prepared in draft, reviewed and commented on by the Bank, and disclosed by Government. Based on a review of preliminary subproject investments identified in the Government’s feasibility studies, the potential environmental impacts of project investments are felt to be minor, temporary, site-specific and reversible, and generally limited to the construction phase of the sub-projects. As such, these impacts would be addressed through the application of basic Environmental Codes of Practice (ECOPs), technical guidance on appropriate construction designs and practices, and a negative list of ineligible sub-project types and expenditure items. These ECOPs are included in the ESMF (which also include guidelines for chance find procedures in the event that project activities accidently encounter artifacts or sites of cultural value). In accordance with the Bank safeguards policies and Government’s environmental protection commitments procedures, investment owners (districts or communes) would be responsible for preparing a short Environmental Management Plan for any subproject for which impacts could not be adequately addressed through the application of the ECOPs. Page 7 of 12 OP 4.36 on Forests has also been triggered given the fact that approximately 50 percent of the project area is forests or forest lands. Analysis of rural livelihoods in the project area indicates that access to forest resources (including non-timber forest products) is an important strategy for poor Public Disclosure Copy ethnic minority households. Potential livelihood activities (under component 2) that would require consideration of this policy include tree crops (acacia, litsea or cacao) or other agriculture activities to be undertaken on production forest lands. For these purposes, the EMSF will require that community groups (LEGs) prepare a community forest management plan (CFMP) that would be reviewed by local authorities (forest extension services) at district level to ensure that proposed activities comply with pertinent national laws on the use of these lands. The CFMP aims to assist communities to (a) sustainably manage forests and forest lands, (b) stabilize forests and protect water sources, and (c) steadily improve livelihoods by ensuring a stable supply of forest products. The CFMP includes socio-economic information of the project area and a brief assessment of the land use allocations for the management, conservation, and sustainable development of forests. The socio-economic assessment reviews (a) the extent to which the livelihoods of local communities depend on and use trees, (b) the institutional, policy, and conflict management issues involved in improving the participation of ethnic minorities and poor people in the management of the trees and forests; and (c) forest product and forest service issues relevant to ethnic minority people and poor people, as well as opportunities for promoting the involvement of women. The CFMP is developed using the participatory planning approach and with the support of the project community facilitator. Guidelines for the CFMP are included in the PIM. The Government has also prepared a draft Resettlement Policy Framework (RPF) which, in accordance with OP 4.12 on Involuntary Resettlement, addresses issues relating to land acquisition under the project. A draft RPF has also been prepared by Government, reviewed by the Bank and disclosed. The final RPF will be approved by the Prime Minister’s office prior to project negotiations. The RPF presents the principles and objectives, eligibility criteria of displaced persons, modes of compensation and rehabilitation, participation features and grievance procedures that will guide the compensation and potential resettlement of affected persons. Voluntary land donation would be allowed under very specific guidelines/limitations, to be Public Disclosure Copy outlined in the PIM, and would be monitored closely. At appraisal, although a list of potential investments in the first 18 months has been developed, the precise level of impacts associated with these subprojects is unknown as designs are not yet finalized. Prior to final approval by Government of the annual subproject investment plans, provinces will review subproject designs and prepare an annual resettlement plan based on guidance stipulated in RPF. The Project Implementation Manual would include due diligent procedures concerning project activities involving voluntary land donations to ensure that (i) there are no legacy issues; (ii) such donations meet the Bank's criteria for voluntary land donations; i.e. that they indeed are voluntary, made without coercion and with a choice to say no; and (iii) that in cases where land donations do not meet the Bank's criteria measures are in place to fill such gaps. Ethnic Minorities are the overwhelming majority among the project targeted beneficiaries. Therefore that no separate IPP was developed as all the relevant elements of OP 4.10 have been directly integrated into the design of the project, project documents and Project Implementation Manual and are described in details in Annex 6 of the PAD. As such, the CHPov was designed as an EM project in compliance with OP 4.10 on Indigenous Peoples and therefore meets all requirements of an Ethnic Minority/Indigenous Peoples Plan. In compliance with the mentioned policy, a social assessment (SA) has been undertaken and disclosed prior to appraisal, and the findings of the SA have been used to inform the project’s design. These design features include a communications strategy and materials that apply different and literacy appropriate media forms, Page 8 of 12 preferred recruitment of key field staff (community facilitators) from local communities, the use of indigenous languages in communications at village level when facilitating local decision making, inclusion of elders and traditional leaders as part of village level planning, minimum requirements Public Disclosure Copy for EM participation in decision meetings and livelihoods groups (which will be monitored), technical support and capacity building (including for village groups) around participatory processes, etc. The project will also specifically monitor results and evaluate impacts by ethnic groups. The SA included a gender analysis and assessment and the project will include the following gender informed design elements: minimum requirements for female participation in planning and decision making meetings at village level, a designated female position (of Vice-Chair) for the commune-level decision making board, specifically targeted/ear-marked support for women’s livelihoods activities under one of the project’s sub-components, and monitoring and evaluation data will be gender disaggregated. A broad consultation process was undertaken as part of the project preparation that included the application of participatory processes at village and commune levels to identify or confirm the list of the first 18-month investments. Preparation teams also communicating design options and strategies with implementation partners (government counterpart agencies) and took into consideration opinions of stakeholders at all levels of project implementation and from a significant number of project sites (see following section). Moreover, as a participatory demand- driven project, free, prior and informed consultation that would result in broad community support for project investments will be undertaken before any subproject is approved. This participatory process that explicitly engages with local communities and EM groups would help to ensure that project benefits are culturally appropriate. The process is being elaborated in detail by the Government and will be presented in the PIM. Training in facilitation and participatory processes that would target commune officials and community facilitators will begin in late 2013 in time for projected project effectiveness in early 2014. Public Disclosure Copy The implementing agency for the project, the Ministry of Planning and Investment (MPI), has experience with Bank-financed projects and is familiar with Bank safeguards policies. At central level, MPI will hire qualified consultants to assist in training provincial, district and commune level staff (who would be designated by the relevant authorities) to oversee and ensure the application of the ESMF and the RPF for the subprojects. These same consultants will be hired to periodically monitorthe application of the safeguard frameworks and to provide annual refresher training to the relevant, designated, staff. Project staff and beneficiaries at provincial, district and commune level will be provided training on the relevant World Bank safeguards policies, safeguards coordinators will be designated at district level among the project staff, and safeguards champions will be trained and given responsibility at commune and village level to ensure that relevant mitigating measures for individual sub-projects are implemented. A grievance redress mechanism that would cover all aspects of project management and implementation, including the application of relevant social and environmental safeguards and mitigation measures, would also be included in the project and described in the PIM. 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. The project’s key stakeholders include (i) community members in the target communes and villages that are the primary beneficiaries and active participants in the project, (ii) government Page 9 of 12 officials and civil society groups (women’s union, farmers assoc., etc.) at commune level who would manage and oversee investments at this level, (iii) district and provincial government staff who are responsible for project implementation, and other collaborating departments such as Public Disclosure Copy agriculture and rural development, health/nutrition, and the Committee on Ethnic Minorities, etc., (iv) private sector enterprises (construction firms, agro-businesses, input suppliers, etc.) that would be engaged and/or interested in the project’s commercial aspects; and (v) national government agencies particularly MPI. Formal public consultations were carried out during June 2013 in all 6 project provinces with the participation of key government and civil society stakeholders. Representatives of provincial Departments of Planning and Investment, district peoples’ committee members, and local civil society organizations (e.g. women union, farmer association, and fatherland front) attended the public consultation meetings. Documentation of these consultations (and suggestions received) are presented in the the ESMF. Several consultative workshops were held with participating provinces and districts on project design and implementation in Quang Ngai (April 2013), Sa Pa (June 2013) and Nha Trang (August 2013). Additional consultations with local authorities and community members were also conducted during the social assessment process (started in July 2012), the findings of which are properly included in the project design. Finally, the Government’s project preparation team and the World Bank preparation team have visited all provinces, most districts and approximately 50% of all project communes from January 2012 to August 2013 to discuss the project’s objectives, strategies and activities to solicit inputs from all stakeholders including representatives of the private commercial sectors. These comments and feedback from the project’s ultimate beneficiaries, implementing partners and key stakeholders have been incorporated into the final project design. Prior to project appraisal, all safeguard documents (ESMF, RPF and SA) have been disclosed locally in Vietnamese at the project sites and at the Vietnam Development Information Center. They have also been disclosed in English at the Bank’s InfoShop in Washington DC in accordance with Bank procedures. B. Disclosure Requirements Public Disclosure Copy Environmental Assessment/Audit/Management Plan/Other Date of receipt by the Bank 09-Aug-2013 Date of submission to InfoShop 12-Aug-2013 For category A projects, date of distributing the Executive Summary of the EA to the Executive Directors "In country" Disclosure Vietnam 12-Aug-2013 Comments: Resettlement Action Plan/Framework/Policy Process Date of receipt by the Bank 09-Aug-2013 Date of submission to InfoShop 12-Aug-2013 "In country" Disclosure Vietnam 12-Aug-2013 Comments: Indigenous Peoples Development Plan/Framework Date of receipt by the Bank 09-Aug-2013 Page 10 of 12 Date of submission to InfoShop 12-Aug-2013 "In country" Disclosure Vietnam 12-Aug-2013 Public Disclosure Copy Comments: The overall project design complies with the Bank’s policy on Indigenous Peoples given that the majority of the project’s beneficiaries (over 72 percent) are members of EM groups, that the project specifically targets these groups to benefit from the project, and that the main project strategy is based on participatory development approaches that specifically engage these groups in consultative processes. In compliance with OP 4.10, the Government carried out an SA which informed project design, including elements aimed at enhancing participation and inclusion of EMs. Pest Management Plan Was the document disclosed prior to appraisal? Yes Date of receipt by the Bank 09-Aug-2013 Date of submission to InfoShop 12-Aug-2013 "In country" Disclosure Vietnam 12-Aug-2013 Comments: In response to OP 4.09, pest management is handled through the use of an Environmental Code of Practice that includes a set of guidelines on sustainable use of pesticides and fertilizers, included in the ESMF 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 Public Disclosure Copy 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 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 4.10 - Indigenous Peoples Page 11 of 12 Has a separate Indigenous Peoples Plan/Planning Framework Yes [ ] No [ ] NA [ ] (as appropriate) been prepared in consultation with affected Public Disclosure Copy Indigenous Peoples? 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 Public Disclosure Copy 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: Name: Sean Bradley Approved By Sector Manager: Name: Jennifer J. Sara (SM) Date: 28-Nov-2013 Page 12 of 12