Page 1 INTEGRATED SAFEGUARDS DATASHEET APPRAISAL STAGE I. Basic Information Date prepared/updated: 03/31/2011 Report No.: 60626 1. Basic Project Data Original Project ID: P106699 Original Project Name: Haiti - Urban Community Driven Development Project / PRODEPUR Country: Haiti Project ID: P121833 Project Name: Housing Reconstruction - Urban Community Driven Development Additional Financing Task Team Leader: Sylvie Debomy Estimated Appraisal Date: September 15, 2010 Estimated Board Date: October 26, 2010 Managing Unit: LCSAR Lending Instrument: Specific Investment Loan Sector: General industry and trade sector (31%);Micro- and SME finance (31%);Banking (30%);Public administration- Finance (8%) Theme: Small and medium enterprise support (100%) IBRD Amount (US$m.): 0.00 IDA Amount (US$m.): 30.00 GEF Amount (US$m.): 0.00 PCF Amount (US$m.): 0.00 Other financing amounts by source: BORROWER/RECIPIENT 0.00 0.00 Environmental Category: B - Partial Assessment Repeater [] Is this project processed under OP 8.50 (Emergency Recovery) or OP 8.00 (Rapid Response to Crises and Emergencies) Yes [X] No [ ] 2. Project Objectives The original Project Development Objective (PDO) is to improve access to, and satisfaction with (i) basic and social infrastructures and services, and (ii) income- generating opportunities for residents of targeted urban slums. These objectives will be achieved through a participatory process in which community-based organizations propose, select, implement, and maintain subprojects. The proposed additional financing will help finance additional project activities in response to the Emergency. (#Emergency# means the extraordinary event of limited duration which was caused by the occurrence of a 7.0 magnitude earthquake in selected parts of the Recipient#s territory and which brought about unprecedented physical, social and economic damage to the Recipient and its population). Page 2 Under the Additional Financing, the PDO would be modified slightly as follows: 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. 3. Project Description The proposed project includes the following three original components: Component 1: Community subproject funding, management, and support (US$ 13.50 million; IDA US$ 12.70 million) This finances subprojects in 10 targeted priority zones of five municipalities. These targeted disadvantaged urban areas fulfill poverty/urban criteria and are traditional flash- point communities and include: Bel-Air/Solino/Ticheri, Martissant/Grand-Ravine/Cite de Dieu/Cite l#Eternel/CitePlus, poor urban section of Cite-Soleil (Metropolitan area of Port-au-Prince); La Fossette/Nan Bannann/Shada, Bas-Ravine/Rival/Fort Bourgeois/Bande du Nord, (Cap Haitien); Kasoley, Raboteau/Jubile Blanc, Descahos/Trousable (Gonaives); and Portail Guepe / Blockhaus / La Scierie, Portail Montrouis/Fressinaut (St. Marc). Specifically, subproject funding would finance: (i) Small-scale socio-economic infrastructure and productive/income-generating subprojects, which are identified either by community associations (CBOs), or jointly by CBOs and municipal governments, and later prioritized by representative Project Development Councils (COPRODEPs) as a function of available resources under the project, and ii) Contracting of service providers to mobilize CBOs to participate in the project, as well as to provide the necessary training and technical assistance to CBOs in the preparation and subsequent execution of subproject investments. Component 2: Capacity-Building and Technical Assistance (US$ 0.90 million) This component finances: (i) Training-of-trainer events in basic management, administration, accounting and financial management for Project Development Councils and municipal government officials; (ii) Capacity building and technical assistance to strengthen governance, participatory development, supervision, and coordination capacity at the municipal government level as well as to relevant ministerial staff; (iii) Workshops with Service providers to harmonize practices to accompany CBOs and Project Development Councils in carrying out the activities under Component 1; (iv) Training of Bureau de Monetisation staff in order to effectively supervise overall project implementation; (v) various consultant services, including possible preparation of future operation and assessment of ways through which the Haitian Diaspora might be mobilized to finance and provide technical expertise to the community sub-projects; and (vi) policy dialogue to engage GOH and other relevant stakeholders on a medium to long- term national strategy to facilitate the mainstreaming of the Urban CDD approach and mechanisms. Page 3 Component 3: Project Administration, Supervision, Monitoring and Evaluation (US$ 2.1 million) This component finances incremental costs associated with project implementation, administration, supervision, monitoring and evaluation (including the establishment and operation of a Management Information System or MIS) by the Bureau de Monetisation through its Project Coordination Unit (PCU/ Bureau de Monetisation), which operates under the oversight of the Ministry of Economy and Finance. Under additional financing (AF), one new component will be supported, namely Housing Repair and Reconstruction (US$29.1 m). This component will help finance the following activities in communities already actively participating in PRODEPUR: # Building debris removal (US$ 2.6 million) # Cash grants for housing repair and reconstruction (US$ 13.6 million). # Community service infrastructure repair, improvement and extension (US$ 7.3 million). # Advisory services for implementation support (US$ 5.6 million). 4. Project Location and salient physical characteristics relevant to the safeguard analysis Disadvantaged urban areas in Cite-Soleil, Port-au-Prince, Cap-Haitien, Gonaives, and St. Marc are eligible for support under PRODEPUR. Cities in Haiti are major environmental #hotspots# that require urgent attention, particularly following the Emergency. Population growth, commercial activity, energy and resource use, and waste generation within these areas have resulted in overloaded natural systems and overwhelmed management systems. Urban areas are inundated with their own wastes as a result of inadequate waste management policies and practices. The impacts of greatest concern are found at the household and community level, and are related to deficiencies in urban infrastructure and services. The urban poor bear the brunt of deteriorated environmental conditions through health and productivity losses and diminished quality of life. The AF component will take place in informal neighborhoods in which the original project (PRODEPUR) has already developed community development councils (COPRODEPs). These targeted disadvantaged urban areas are traditional flash-point communities and were seriously damaged by the Emergency. The Delmas 32 neighborhood has been chosen as a first site to begin activities (other neighborhoods in which PRODEPUR is active are also eligible for support, and in this respect preparation activities are underway in Carrefour Feuilles). These neighborhoods are extremely dense with little community infrastructure, solid waste management or public safety resources. Following the Emergency, the neighborhood has suffered loss of life and property destruction. 5. Environmental and Social Safeguards Specialists Ms Valerie Hickey (YPP) Mr Fabio Pittaluga (LCSSO) Page 4 6. Safeguard Policies Triggered Yes No Environmental Assessment (OP/BP 4.01) X Natural Habitats (OP/BP 4.04) X Forests (OP/BP 4.36) X Pest Management (OP 4.09) X Physical Cultural Resources (OP/BP 4.11) X Indigenous Peoples (OP/BP 4.10) X Involuntary Resettlement (OP/BP 4.12) X Safety of Dams (OP/BP 4.37) X Projects on International Waterways (OP/BP 7.50) X Projects in Disputed Areas (OP/BP 7.60) X 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 original project Project categorization Currently PRODEPUR invests in multiple, small-scale, investments (community subprojects) prioritized by CBOs representing the neediest urban communities across the country. These activities have not, to date, produced any large-scale, significant and/or irreversible impacts, nor are they expected to. Given the poor environmental conditions of the urban areas (e.g. lack of waste management systems) many of the rehabilitation works would improve the environmental health of project intervention areas. Potential negative impacts (direct, indirect, and cumulative) related to construction, operation and maintenance phases of any subproject, in particular for civil works, are mitigated and/or avoided under guidance provided in the existing ESMF. These measures are identified and assessed during subproject preparation and included (with associated costs) in contractor contracts. Using the PRODEPUR community-based, participatory approach, the potential scale of environmental impacts arising from the proposed AF activities will remain small-scale and non-significant despite the post-disaster context. The ESMF has been updated to provide further guidance on mitigating impact types that have not been addressed in the current ESMF. This updated ESMF provides guidance on identifying, minimizing, mitigating and managing all activities. As such, we recommend that the Project retain its environmental category B. Safeguard instruments The project#s Environmental and Social Management Framework (ESMF) is embedded in the project#s Operational Manual. This ESMF already incorporates lessons learned from the implementation and application of the ESMF for the PRODEP project, and builds upon three key instruments that have been developed and used under PRODPUR to identify and minimize the potential environmental impacts of its subprojects, namely: Page 5 (a) a map of sensitive areas in each community; (b) community level diagnostics setting forth key environmental constraints; and (c) standard environmental management plans for common subproject types (e.g. steps to minimize and mitigate impacts arising from common construction activities). The ESMF, in accordance with national law and international best practice, includes: (i) subproject screening and classification based on potential environmental impacts of the project type and site sensitivity; (ii) decision-support matrices for identifying the required environmental work (which sub-projects require what type of Environment Management Plan (EMP)); (iii) a monitoring and evaluation section to supervise the implementation of appropriate mitigation measures; and (iv) institutional arrangements. The ESMF has been updated in light of the proposed activities to include measures and principles for dealing with debris removal and worker health and safety (as well as potential involuntary resettlement, all of which are described below). Currently subprojects are declared ineligible if they are located within a critical area. The definition of critical areas will be updated based on the results of a multi-hazard risk assessment that will identify those portions of each neighborhood where reconstruction is inadvisable given the risk of flooding, landslides, etc. Based on lessons learned from implementing the ESMF, the timing of safeguards interventions will also be updated. Initially, screening occurred prior to the completion of technical designs for each sub-project. While this is still important to screen out ineligible sub-projects prior to sinking funding in preparation, the ESMF now includes procedures to also reevaluate the screening following the completion of technical designs to ensure that all potential impacts are captured, assessed and mitigation activities identified. Additional financing activities Scale and scope of potential adverse environmental impacts: Given the poor environmental conditions of urban areas, particularly due to the lack of waste management systems, the proposed rehabilitation and reconstruction works would greatly enhance the environmental health of these areas. Potential negative impacts (direct, indirect, and cumulative) related to the construction and rehabilitation of the neighborhoods would mainly comprise reversible and manageable small scale construction impacts. The main direct impacts are expected to occur during construction and cause localized negative environmental impacts, consisting mostly of worker safety issues, noise, vibration, dust, and access disruption. Based on the experience of housing reconstruction following the tsunami in Aceh and the earthquake in Yogyakarta, Indonesia, the likely key environmental risks associated with reconstruction activities for this type of project include: depletion of natural resources from increased demand for construction materials and impacts associated with changes in removal of debris. Because the neighborhoods access potable water from Page 6 stand pipes attached to springs rather than from groundwater, there are scant health impacts in this area. Building Materials. Cumulative environmental impacts of procurement of construction materials (including timber, bricks, cement and sand) associated with the overall reconstruction effort will be significant. However, assessing this impact is very complex and well beyond the scope of the PRODEPUR project. Moreover, the net effect of this project#s demand for materials will be a very small percentage of this overall impact, especially in light of the amount of existing housing materials that can be reused. Nonetheless, the project will ensure that it minimizes the use of new construction materials, these materials meet new national standards that the GoH is finalizing, and procures these only from legal and reputable sources. Management of Debris. The clean-up of debris may not be a significant issue at the household level, but is an issue at the large scale, particularly in terms of final disposal. The initial urgency to clear debris in order to recover bodies has led to fairly indiscriminate dumping of debris in the neighborhoods, causing blockages to water canals which in turn can cause localized flooding in the rainy season. All debris will be cleaned up and managed prior to the initiation of individual reconstruction. The final management (including reuse and final disposal) of debris is an important contextual issue for this project, and is being addressed through parallel and complementary approaches, including through the Bank- financed Emergency Infrastructure project that is building the capacity of the Truitier Landfill to accept and properly manage debris and other wastes. The project will finance the preparation of a Debris Management Plan that will emphasize how debris will be collected and managed at the source site (up to arrival at Truitier). This plan will be finalized, consulted on and disclosed prior to the beginning of works in each neighborhood. It will include procedures for dealing with any human remains found in the wreckage, procedures that in turn will be based on the UN Office for the Coordination of Humanitarian Affairs guidelines (included in the ESMF). Worker health and safety. Training in the use of construction equipment will be provided through the Community Reconstruction Center. Personal protective equipment will be made available, and its supply and proper use will be added in contract clauses for debris removal. Physical Cultural Resources. It is possible that the civil works might directly and/or indirectly affect cultural property in existing neighborhoods. These could include known local structures or sites of historic or cultural importance. Given the human cost of the Emergency, it is also possible that some sites will be accorded religious significance. The highly participatory nature of the project coupled with the screening procedures outlined in the ESMF will ensure that communities would be able to identify if any proposed sub- project will have an impact on cultural property as defined by the policy. Sub-project proposals will require the identification of any such activities and require the CBO proposing the sub-project to specify adequate mitigation measures. This process is Page 7 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. The following policies are not triggered, as explained below: Natural Habitats and Forests. Project activities will occur exclusively in urban neighborhoods that are highly degraded. Moreover, the existing ESMF already includes screening procedures to ensure that no project interventions occur or affect these critical habitats. In addition, the Project team will work with parallel initiatives to ensure that sourcing building materials for its activities will not lead to adverse impacts on the natural environment or remaining natural forests in Haiti, or that effective mitigation measures are in place to manage these impacts. Pest Management. The project will not result in vector management (VM) to prevent, reduce or eliminate the transmission of disease through risk vectors (such as rats). As a result, the procurement, storage or use of pesticides will remain ineligible under PRODUPUR. Consultations and Disclosure: BMPAD and PADF will work through the COPRODEPs to consult with local communities regarding the proposed project activities, potential adverse impacts, proposed safeguard instruments and the existing grievance mechanism prior to the commencement of works. Local peoples will remain engaged throughout the life of the project through the creation of Community Reconstruction Centers in each neighborhood that will house community liaisons and technical assistants, and will serve as a platform to provide trainings, host consultations, disclose materials and collect and address complaints. The updated ESMF will be disclosed to affected peoples and other stakeholders, both locally and through the InfoShop, upon completion, by July 1 2011 and prior to the beginning of works under Component 4. Scale and scope of potential adverse social impacts: A Social Assessment (SA) originally carried out during project preparation for PRODEPUR helped to define the physical delimitation of the target areas and produced socioeconomic data and information about CBOs working in those areas; it also identified social issues that can affect project implementation, as described below. The key social issues that relate to Component 4 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) Page 8 addressing physical relocation that may be necessary as a result of house repair, reconstruction or community infrastructure development. 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) develop an adequate resettlement framework 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 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, a rapid social analysis will be conducted in consultation with the key stakeholders to identify any additional, critical social issues, and to solicit suggestions on how to best address them. The ongoing PRODEPUR project has a strong record of community-based planning and implementation, which is a key, positive factor in promoting smooth preparation and implementation of the proposed additional financing program. Under PRODEPUR, each COPRODEP, a strong umbrella community organization empowered in each neighborhood (for example, the COPRODEP in Delmas 32 comprises sixty three constituent community-based organizations), has already demonstrated their capacity to successfully implement community-based initiatives. They have been involved in debris removal, implementing cash for work programs, and distributing survival kits, clean water and lanterns. It is important that the COPRODEPs continue to play a key role in helping design program activities to be supported under the additional financing, and in overseeing their implementation. The key social issues, and how the program will address them, are described below: Accurate identification of beneficiaries living in project intervention areas:The engineers from MTPTC have been working with social workers from PADF and UNOPS to divide all dwellings into the three categories (red, yellow, green) and identify the specific families that lived in each affected house. This information includes some household demographics, property measurements and tenure status of each of the affected properties. However, this information is not complete. The additional information required will be gathered through a community-based mapping exercise. A Manual for Community-based Mapping, which is currently being prepared by UN Habitat, will be used in this effort. Page 9 Determining the property tenure status of each beneficiary: The community-based mapping exercise will help determine whether the family residing in each property is an owner of the house they occupy, or a lessee, a sub-lessee etc. The tenure classification will also be based on whether the owner resides in the neighborhood or is an #absentee owner#, and whether the land on which the house is constructed is owned by the owner of the house. The activities supported under this AF will be implemented without prejudice to the property tenure status of the owners and occupants, in the spirit of providing urgently required assistance to ensure safe shelter for families that have severely suffered in the aftermath of the earthquake. The typology of land tenure under this project is likely to include: # owners residing in their own houses (who also own the land) # renters, renting from owners residing in the same house (also own the land) # renters, renting from absentee owners (in the country, and own the land) # renters, renting from absentee owners (living in a foreign country, but own the land) # renters, renting from renters (sub-renters) # all of the above categories, but where the owner / occupant does not own the land # owners / renters of #red houses# that will be demolished. Land tenure and property tenure issues in the Haitian context are particularly intricate and complex, have a long standing history and beyond the scope of this project to resolve. Nevertheless, two specific measures are being contemplated to facilitate field interventions under the proposed AF: (i) carrying out community-based mapping to collect information on the demographics and tenure status of residents and on the physical boundaries/characteristics of affected land parcels and buildings, and (ii) establishing grievance mechanisms to address concerns raised by beneficiaries during the reconstruction process. The community-based mapping exercise will help legitimize tenure claims that cannot be substantiated with formal documentation, and will occur with the participation of formal authorities, CBOs and beneficiaries. The grievance mechanisms will address contested outcomes or unclear processes. Defining options for assistance: Based on the information from the Community-based mapping exercise, the Multi-hazard Risk Map and the Urban Planning Map, a number of options for providing assistance to the eligible beneficiaries will be developed. Beneficiaries will be limited to houses marked red or yellow. Red houses will be demolished and rebuilt or repaired. Yellow houses will be repaired. The forms of assistance will be finalized in consultation with key stakeholders including the community-based organizations, various government agencies involved in the reconstruction effort and the beneficiaries of the project. All assistance will be provided the women in the households. The model of support will be based on community-based reconstruction methods that have been successfully implemented in Indonesia, Afghanistan and Pakistan. The form and extent of project support to be provided to the communities, as well as the detailed provisions of how the program will be implemented and supervised, will be included in the amended OM. Page 10 The issue of renters and sub-renters: Since a large number of affected families were / are renters, measures will be identified to ensure that they have continued access to rental housing after the house repairs have been completed. This will also include inhabitants of red houses. Measures to support vulnerable groups: Among the beneficiaries, there are likely to be particularly vulnerable beneficiaries who may need special assistance.These may include women, especially female-headed households, orphan children households, households with old parents where the children may have died etc. Special provisions for them may include: (a) support in house repair/reconstruction, (b) higher amounts of assistance for reconstruction, (c) support for accessing various relief/development programs being administered by others, (d) regular, targeted consultations with, and monitoring of these groups during project preparation and implementation, (e) rental subsidies and/or ad hoc grants to deal with special circumstances (e.g. orphan children). Involuntary Resettlement: Subprojects are not expected to require involuntary resettlement since the sub-grants for Emergency reconstruction will finance settlement (housing and community infrastructure) rehabilitation and reconstruction in-situ. In the event they do, however, a Resettlement Policy Framework (RPF) is in preparation in accordance with OP4.12 to ensure application of the appropriate safeguard policies. 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, 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 animateurs 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. No land acquisition will be supported under the project. Consultations and Disclosure: BMPAD, with help from the MDODs and COPRODEPs will consult with project affected peoples and other stakeholders on the RPF prior to its finalization and before works begin. These consultations will continue through the life of the project. The RPF will be disclosed both locally and internationally through the proposed neighborhood Community Reconstruction Centers, existing social networks, and the World Bank website (www.worldbank.org) by July 1, 2011. Page 11 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. 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. Two alternatives to the proposed AF were considered. A first alternative examined was to support initiatives by various NGOs and other international organizations such as UNOPS focusing on the provision of transitional shelter to avoid environmental impacts associated with permanent construction. The alternative was rejected based on the Bank#s experience with other post-disaster reconstruction programs in, for instance, Indonesia, Pakistan and India which showed that the building of transitional housing did not provide a lasting solution nor did they necessarily reduce short-term impacts from construction. A second alternative suggested was to modify the institutional arrangements of PRODEPUR to include a window for large public investment-type reconstruction operations within the Project municipalities. This alternative was rejected because relocating Emergency victims to standardized mass housing complexes was likely to further disrupt the already fragile social fabric of the communities and lay the ground for a rapid resurgence of crime and political violence. Moreover it would not lessen environmental impacts. An alternative to Truitier Landfill was also proposed for debris management. The site, at the Varreux Port, was used as the main debris sorting site for all US Government collected debris during the March-early June 2010 period in the immediate aftermath of the Emergency. However, the Varreux Port site is private land and an agreement had to be made with the private owner for temporary use of the site as a debris sorting area in return for use of some of the clean fill. During the sorting operations, US Government reported that the owner interfered with operations by diverting some of the trucks carrying debris to another nearby site on his land. General debris and refuse was also being used to extend the existing jetty in the northwest corner of the property further out to sea. In addition to the public scavenging debris as it was being dumped, there was no organized staging, sorting, or processing of debris materials. Consequently all types of mixed debris, including some garbage and trash, were being used as backfill for land reclamation at the ocean#s edge. The other adverse issues with site operations included unlimited access by the public, which could cause serious injury around heavy equipment and potential exposure to contaminated waste. Given this situation, USAID determined that a new site for debris sorting was needed, and in collaboration with the World Bank, a plan for a new temporary debris sorting operation at the Truitier site as a separate component of the overall landfill development is currently under preparation. It is to this site that debris will be taken from project intervention areas. Page 12 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. Safeguard Instruments. The Borrower has prepared an Environmental and Social Management Framework (ESMF) in accordance with OP 4.01 and the national environmental decree. The ESMF includes procedures for the screening of all subprojects and sites, application of mitigation measures to offset identified impacts, regular environmental monitoring, and environment-related technical assistance. Many of the priority sub-projects identified by the communities under the project relate to income generation. Moreover, depending on the context and the neighborhood, the socio-economic activities as well as the ecological specificities/sensitivities differ. Both the CDD subproject and municipal subproject windows take into account the ecological/environmental and social dimensions of the urban areas as well as the scope and magnitude of the proposed subprojects within the preparation and implementation cycle. Specifically, the project#s ESMF incorporates in the selection process of subprojects criteria to ensure compliance with environmental and social safeguards. Under this AF, the project#s ESMF has been updated based on the integrated lessons learned from the ongoing subproject preparation and implementation cycle. A Debris Management Plan will be prepared prior to the beginning of debris removal. A draft Resettlement Policy Framework (RPF) has been prepared to guide responses in the event that any involuntary resettlement, as defined under OP 4.12, occurs. Borrower Capacity. On behalf of the Government of Haiti (GoH), the Bureau de Monétisation des Programmes d#Aide au Développement (Office of Monetization of Development Aid Programs) (formerly the PL-480 Management Office), under the Ministry of Economy and Finance (MEF) and through its existing Project Coordination Unit (PCU/Bureau de Monétisation, BMPAD), will retain overall responsibility for implementing this component of PRODEPUR. The other entities involved in project implementation include Community-Based Organizations (CBOs), Project Development Councils (COPRODEPs), the Service Providers (MDODs), and the municipal government. These implementation arrangements remain the same as those being used in the parent project. National government: The Bureau de Monétisation is an autonomous public institution created in 2007 to: (a) receive and monetize food aid from the international donors, and (b) identify and fund government development projects with relevant institutions and/or agencies in areas such as road construction, agriculture, education, health, and commerce. As the national executing agency of the project on behalf of the Government of Haiti (GoH), BMPAD will be responsible for overall project coordination and oversight, but will delegate day-to-day project execution to the MDODs. BMPAD will nonetheless provide continuous oversight of (i) the environment and social impact screening process; Page 13 (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 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 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. BMPAD#s comprehensive Operational Manual includes the ESMF. This has been satisfactorily applied to date. Their team also includes highly capable safeguards staff. As such, BMPAD has exhibited sufficient capacity to undertake further safeguards implementation under the AF component. Nonetheless, because of the increased number of sub-projects to be managed and supervised, BMPAD has agreed to more than double its current staffing for safeguards. Local government: Despite Haiti promulgating a legal framework for decentralization under the 1987 Constitution # to give citizens a voice in local politics and to provide citizens with basic services through the establishment of a functional local administration # the decentralized system remains barely functioning. There are three categories of local governments (collectivités territoriales), each with both executive councils (conseils) and legislative assemblies (assemblées), as follows: (a) the section communale, with an Administrative Council of the Communal Section (Conseil d#Administration de la Section Communale, CASEC) and a Communal Section Assembly (Assemblée Section Communale, ASEC); (b) the commune or municipality, with a three-member municipal council (headed by a mayor) and a municipal assembly; and (c) the départment, with a departmental council and a departmental assembly. All bodies exercise financial and administrative autonomy, but only the commune is empowered to levy taxes. As a result, the section communal and the departments are fully dependent on budget appropriations from the central government. Only the municipalities play a direct role in the project. The involvement of municipalities in disadvantaged urban areas is particularly uneven and suffers from lack of a clear legal and regulatory framework that can give coherence and supervision to the multiple municipal development initiatives in urban areas or take responsibility for planning and technical issues. In addition, in large urban centers there exists a large distance between the community initiatives at the local neighborhood level Page 14 and the commune structure. Complicating this is the fact that no official subdivisions exist within cities; the municipal council and the municipal assemblies technically represent the entire commune, not just the city itself. In terms of project activities, municipalities can occupy up to 20% of the seats on each COPRODEP, and are eligible to submit project proposals in association with a community-based organization (CBO). Nonetheless, while municipalities# capacity for safeguards will be enhanced through BMPAD-led training, they will not have a supervisory role in identifying, minimizing, mitigating or managing actual impacts except through their voice on the COPRODEPs or as sub-project implementers should their proposals be accepted. Project Development Councils (COPRODEPs): COPRODEPs are formed by elected representatives of CBOs, civil society, and local/municipal government representatives (who are eligible for less than 20% of seats). As the principal entity for targeting benefits and allocating project resources at the communal level, COPRODEPs also provide a critical link to local government and have the potential to engage in other non-project activities. COPRODEPs play a fundamental role in mobilizing communities and promoting their participation in local decision- making. This will be an especially important role in supervising community mapping, verifying tenure and consulting with project-affected peoples in the AF component, something that as a participatory and representative community body, the COPRODEPs are very well suited to do. Service Providers (Maîtres D#Ouvrage Délégués, MDOD): Under the overall guidance of BMPAD, the main service provider whose primary responsibility is the implementation of sub-project activities is the Pan American Development Foundation (PADF), and in some cases, the Center for International Studies and Cooperation (CECI). Their role comprises: (a) assisting CBOs and COPRODEPs in strengthening their organizational and operational capacities; (b) accompanying CBOs and COPRODEPS in the #on-the-ground# execution of subproject activities (including community-based mapping); (c) providing technical assistance to CBOs throughout the subproject cycle; (d) technically appraising subproject proposals approved by the COPRODEPs; (e) entering into subproject agreements (contracts) with CBOs for the financing of subprojects (and with other firms for debris removal); and (f) transferring funds for subproject execution directly to the joint MDOD/CBO bank account. To date, under the PRODEPUR and PRODEP projects, PADF and CECI have undergone several trainings in safeguards assessment and implementation. Based on the need to assess sub-projects more closely for involuntary resettlement, further training will be provided prior to the start-up of this AF component. In addition, these MDODs have already hired several community animateurs to work closely with the local community to provide trainings, technical assistance and oversight. This model will be continued during the AF component and more animateurs will be hired. Community-Based Organizations (CBOs): Page 15 CBOs represent groups of neighborhood residents (ranging in size from 25 to 200 members) with common interests that organize into formally constituted civil associations. Within the subproject cycle, CBOs are responsible for the identification, preparation, implementation, supervision, operation, and maintenance of community subprojects, with technical assistance and training from the MDODs and COPRODEPs. CBOs are also responsible for the hiring of consultants and/or contractors throughout the subproject cycle, including to implement or develop environment mitigation measures. Capacity building The project#s existing Environmental and Social Management Framework (ESMF) will be updated to include the training activities that will be given to all participants who will have responsibilities for safeguard implementation under the newer components. It will distinguish among their different training needs in terms of raised awareness, sensitization to the issues, and detailed technical training: # Detailed technical training for project implementers who will need to analyze potentially adverse environmental and social impacts, to prescribe mitigation approaches and measures, and to prepare and supervise the implementation of management plans. This training will address such matters as community participation methods; environmental analysis; using the EMF checklist; preparing Environmental Management Plans (EMPs), Resettlement Actions Plans (RAPs), and so forth; safeguard reporting; and subproject supervision and monitoring. # Awareness-raising for additional stakeholders who may need to appreciate the approach or play a role in the implementation of the project (e.g. contractors; partner NGOs, etc.). # Awareness-raising for beneficiaries who need to be familiar enough with the approach that they can make informed and specific requests for technical assistance. 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, NGOs, and related government agencies. The Borrower has made the ESMF available in country (advertised in local newspapers in Marcy, 2008) and through the Banks InfoShop (also in March 2008). The Borrower also held an initial public consultation workshop in Port-au-Prince on March 5, 2008, during which stakeholders were invited to comment on the draft ESMF. The final ESMF includes a summary of the consultation, including attendees, issues raised and how the final instrument addressed those issues. The project will continue to be implemented under a participatory approach, as follows: Communication and Dissemination campaigns: These campaigns, which have incorporated activities linked to local history and culture (music, dancing, etc.) have been very useful to promote community participation. The recruitment of local consultants to support this activity has contributed to its success. PRODEPUR will continue these activities, incorporating a general strategy targeting selected groups (youth, women, etc.) to better use the resources and have greater impact. Page 16 More broadly, a communication strategy will be developed to promote a genuine, community-led process that is perceived as fair and meaningful by all stakeholders. This will include consulting on project timelines, eligibility criteria, and assistance packages. Preliminary results from the community-based mapping exercise will be shared with each community in a transparent manner, to invite comments or potential objections from community members on the process or the results of the exercise. BMPAD and the MDODs will continue to work through the COPRODEPs to also consult with local communities regarding the proposed project activities, potential adverse impacts, proposed safeguard instruments and the existing grievance mechanism prior to the commencement of works. Local people will remain engaged throughout the life of the project through the creation of Community Reconstruction Centers in each neighborhood that will house community liaisons and technical assistants, and will serve as a platform to provide trainings, host consultations, disclose materials and collect and address complaints. Community-based organizations (CBOs): CBOs will continue to be the foundation of the project under PRODEPUR. The project will reinforce selectivity criteria, improve training, and address some logistic problems hindering participation (transport costs, timing of training, etc.) Project Development Councils (COPRODEPs): COPRODEPs will receive support under the project to better perform its functions: assessment, approval and follow up of subprojects. Training and technical assistance will be provided to reinforce their role to promote social cohesion and address conflicts. B. Disclosure Requirements Date Environmental Assessment/Audit/Management Plan/Other: Was the document disclosed prior to appraisal? N/A Date of receipt by the Bank 03/28/2011 Date of "in-country" disclosure 04/28/2011 Date of submission to InfoShop 04/28/2011 For category A projects, date of distributing the Executive Summary of the EA to the Executive Directors Resettlement Action Plan/Framework/Policy Process: Was the document disclosed prior to appraisal? N/A Date of receipt by the Bank 03/28/2011 Date of "in-country" disclosure 04/28/2011 Date of submission to InfoShop 04/28/2011 Indigenous Peoples Plan/Planning Framework: Was the document disclosed prior to appraisal? Date of receipt by the Bank Date of "in-country" disclosure Date of submission to InfoShop Pest Management Plan: Page 17 Was the document disclosed prior to appraisal? Date of receipt by the Bank Date of "in-country" disclosure Date of submission to InfoShop * If the project triggers the Pest Management and/or Physical Cultural Resources, 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: Disclosure will happen no later than July 1, 2011, and before any activities that have safeguard implications. C. Compliance Monitoring Indicators at the Corporate Level (to be filled in when the ISDS is finalized by the project decision meeting) OP/BP/GP 4.01 - Environment Assessment Does the project require a stand-alone EA (including EMP) report? Yes If yes, then did the Regional Environment Unit or Sector Manager (SM) review and approve the EA report? Yes Are the cost and the accountabilities for the EMP incorporated in the credit/loan? Yes OP/BP 4.11 - Physical Cultural Resources Does the EA include adequate measures related to cultural property? Yes Does the credit/loan incorporate mechanisms to mitigate the potential adverse impacts on cultural property? Yes OP/BP 4.12 - Involuntary Resettlement Has a resettlement plan/abbreviated plan/policy framework/process framework (as appropriate) been prepared? Yes If yes, then did the Regional unit responsible for safeguards or Sector Manager review the plan? Yes The World Bank Policy on Disclosure of Information Have relevant safeguard policies documents been sent to the World Bank's Infoshop? No Have relevant documents been disclosed in-country in a public place in a form and language that are understandable and accessible to project-affected groups and local NGOs? No All Safeguard Policies Have satisfactory calendar, budget and clear institutional responsibilities been prepared for the implementation of measures related to safeguard policies? Yes Have costs related to safeguard policy measures been included in the project cost? Yes Does the Monitoring and Evaluation system of the project include the monitoring of safeguard impacts and measures related to safeguard policies? Yes Have satisfactory implementation arrangements been agreed with the Yes Page 18 borrower and the same been adequately reflected in the project legal documents? D. Approvals Signed and submitted by: Name Date Task Team Leader: Ms Bernice K. Van Bronkhorst 08/31/2010 Environmental Specialist: Ms Valerie Hickey 08/31/2010 Social Development Specialist Mr Fabio Pittaluga 08/31/2010 Additional Environmental and/or Social Development Specialist(s): Approved by: Regional Safeguards Coordinator: Mr Glenn S. Morgan 09/02/2010 Comments: Sector Manager: Ms Ethel Sennhauser 11/02/2010 Comments: