INTEGRATED SAFEGUARDS DATA SHEET APPRAISAL STAGE Report No.: ISDSA3258 Public Disclosure Copy Date ISDS Prepared/Updated: 12-Nov-2013 Date ISDS Approved/Disclosed: 18-Nov-2013 I. BASIC INFORMATION 1. Basic Project Data Country: Argentina Project ID: P133195 Project Name: Argentina Second Rural Education Improvement Project - PROMER-II (P133195) Task Team Peter Anthony Holland Leader: Estimated Estimated 20-Mar-2014 Appraisal Date: Board Date: Managing Unit: LCSHE Lending Investment Project Financing Instrument: Sector(s): Secondary education (40%), Pre-primary education (10%), General education sector (30%), Public administration- Education (20%) Theme(s): Education for the knowledge economy (20%), Rural services and infrastructure (35%), Education for all (20%), Administrative and civi l service reform (10%), Indigenous peoples (15%) Is this project processed under OP 8.50 (Emergency Recovery) or OP No Public Disclosure Copy 8.00 (Rapid Response to Crises and Emergencies)? Financing (In USD Million) Total Project Cost: 275.00 Total Bank Financing: 250.50 Financing Gap: 0.00 Financing Source Amount Borrower 24.50 International Bank for Reconstruction and Development 250.50 Total 275.00 Environmental B - Partial Assessment Category: Is this a No Repeater project? 2. Project Development Objective(s) The proposed Project Development Objective is to support national Government policy to i) reduce Page 1 of 12 repetition in primary education; and ii) increase enrollment and completion in secondary education, in Argentina's rural areas. 3. Project Description Public Disclosure Copy The Project would be comprised of three components. The first, covering pre-primary, primary and secondary education, would aim to reduce repetition rates in rural classrooms, through improvements in teaching and school directors’ management practices and strengthening the school-family linkages. The second component would focus on increasing enrollment and completion of secondary education, through expanding coverage of services. The third component consists of activities related to Project management, monitoring, and evaluation. Given Argentina’s federalist nature, the precise implementation arrangements for components would need to be adapted to the specific conditions of each province, given that similar programs may already be underway in certain areas, in which case PROMER II could support those interventions granted they fulfill certain criteria defined by the National Ministry of Education. Component 1: Reduce Repetition Rates in Rural Classrooms (US$59 million) This Component would consist of two parts: 1.1 Improving teaching and school management; and 1.2 strengthening the link between schools and families. Under PROMER I, much progress was made in reaching out of school preschool-aged children, helping to reduce the number of six year olds in grade one that had never attended preschool by more than half. Still, the school readiness of children entering grade one can be improved upon, as evidenced by the persistently high repetition rate in rural areas throughout primary. Although the teacher training financed under PROMER I helped this effort in part, the chosen training model was to provide intense, long-term training to a select few teachers (postítulo), with insufficient focus on pedagogy. The in-service training provided under PROMER I did not include school directors and supervisors hence excluding, among other things, school-level tools for identifying students at risk of repetition and interventions to remediate the problem. Under component 1.1 of the Project, a new training strategy for in-service teachers, principals and supervisors would be designed and implemented, in accordance with the recently Public Disclosure Copy approved National Plan for Teacher Training (Plan Nacional de Formacion Docente). PROMER I also fostered greater links between schools and communities, and established the mechanisms for transferring small resources for schools to manage independently with the condition of developing an improvement plan. Component 1.2 of the Project seeks to support the further development of this approach, with a view toward fostering greater participation from parents and communities, so as to better engage them in the learning of their children, thereby enhancing their children’s schooling performance (including reducing repetition and dropouts). Component 1.1: Improving teaching and school management This Component would support Argentina’s recently approved National Plan for Teacher Training, through efforts to improve teaching and school management, including designing and implementing an in-service training strategy for all pre-primary, primary and secondary rural schools for teachers, school directors and supervisors. Among the activities to be financed would be the definition of minimum standards for rural teachers, directors and supervisors, design of the training courses to ensure that all rural teachers, directors and supervisors reach minimum standards, design of the training’s rollout strategy to prioritize among those most in need, stipends for trainers, transportation costs, training costs, the development of new teaching and training materials, and the printing and distribution of existing materials. Special consideration would also be given to designing training/ teacher support systems that work with indigenous schools, working to address challenges identified Page 2 of 12 in the diagnostics and corresponding school improvement plans (see Component 1.2). Training courses for teachers would be organized per level of education, focusing on both the Public Disclosure Copy particular needs of that level, as well as the linkages with previous and subsequent levels of education. For school directors and supervisors, training activities would be developed in order to better ensure institutional support for the improved teaching practices, implementation of the learned pedagogic approaches/tools for rural schools and the development and implementation of tools for identifying students at risk of repetition. As such, selection for participation in training would be at the school level, allowing for school teams to develop school-specific projects to address identified challenges. The training would also include instructions for directors in carrying out diagnostics of school problems, developing corresponding school improvement plans, and strengthening the outreach activities with families and communities(Component 1.2). Including teachers, school directors and supervisors in the National Training Plan and defining the school as the level of intervention, has the advantage of triggering synergies and potential interaction effects among the three interventions. Component 1.2 Strengthening the link between schools and families This Component would build on the activities fostering local and social participation under PROMER I. With the view of fostering greater participation of parents and other community members in the learning of children, the Component would strengthen the links between schools and local community. In general, small funds would be co-managed by school management committees consisting of school administrators/representatives, parents association, and community representatives, in order to carry out the activities such as: i) sharing of experiences at the level of the agrupamiento (including financing transportation costs where needed); ii) simple preventive maintenance of schools, such as fixing broken windows; or iii) purchasing needed equipment (e.g. a refrigerator for the kitchen). Access to the small funds would be subject to a school improvement plan developed by the school management committee and the fulfillment of the teacher, principal and supervisor training plan for selected schools as described in Component 1.1. The school Public Disclosure Copy improvement plan must include a diagnostic of the school with basic performance indicators like repetition, dropout and efficiency rates. The school improvement plan should make explicit how the additional funds will be used in any of the three activities listed above (or a combination of them). School improvement plans will be followed by an end-of-year report, developed by the school management committee, describing how the funds were used. Component 2: Increasing Enrollment and Completion of Rural Secondary School (US$180 million) This Component would consist of expanding the supply of secondary education services in rural areas including infrastructure for new schools, increasing capacity for existing schools, school maintenance, learning material and the supply of qualified teachers. The focus under PROMER I has thus far been at the primary and lower secondary level, since that is where demand has been highest. As discussed in the sectoral background, the remaining coverage gap is mainly in upper secondary, hence this Component would focus on expanding supply at that level while still contributing to the expansion of lower secondary, as well as investments in other levels of education where needed, which serve as important pull factors for increasing coverage at higher levels. This Component would strive to increase enrollment in secondary education in rural areas through the expansion of education supply at upper and lower secondary levels, as well as other levels where needed. Among the activities to be financed would be infrastructure and equipment, technical Page 3 of 12 assistance to identify the areas or regions with an infrastructure shortage, didactic materials and the provision or qualified teachers. Public Disclosure Copy To address the infrastructure shortage, a map of underserved areas would be developed to locate demand and help determine the best service delivery models for each selected area. Wherever possible, the unit of analysis for the maps, and the subsequent areas for prioritization, would be the agrupamientos. The pedagogic and institutional approaches to be supported under this Component would strive to address the two main bottlenecks to expanding secondary education supply: the dearth of qualified teachers, and insufficient infrastructure. To address the shortage of qualified teachers, the expansion of the Horizontes program would be the main activity for increasing supply in lower secondary, since it offers a sustainable alternative that relies less on subject area teachers. Launched in 2006, the program organizes teaching around six areas: Spanish, math, social sciences, natural sciences, art, and English. The backbone of the program is especially designed resource manuals featuring concepts for each area, containing individual and group work activities, organized by self-standing units that have parameters for evaluation, and allow students to advance through the material progressively, once the previous unit has been passed. This allows students to move at their own pace, all the while protecting a certain group dynamic. Component 3: Strengthening Project Management, Monitoring, and Evaluation (US$11.5 million) This Component would consist of two parts: 3.1 Project management and 3.2 Monitoring and evaluation. Component 3.1: Project anagement As per the first phase of PROMER, Project management entails: (i) the technical coordination within the MEN across technical departments; (ii) the planning, monitoring, and evaluation of province- Public Disclosure Copy level activities; and (iii) the fiduciary oversight for all Project activities, including financial management, procurement, and all legal aspects of the Project, including safeguards. The Project Management structure is based on existing structures within the national and provincial education ministries. To assure quality implementation of Project activities, the Project would support technical departments through financing just-in-time consultancies and other technical support as required. Two specific technical assistance projects will be developed under this Component: (1) best international practices and other inputs needed for the design of the training strategy for teachers, principals and supervisors, including the definition of standards; and (2) a map of underserved areas to locate demand for secondary education and help determine the best service delivery models for each selected area. Component 3.2: Monitoring and evaluation Working closely with the National Directorate of Information and Evaluation of Educational Quality (Dirección Nacional de Información y Evaluación de la Calidad Educativa – DiNIECE), the Project management team would be responsible for the monitoring and evaluation of Project activities. The Project would finance the Project´s monitoring of indicators and the development of a system to track the implementation of activities and trends in basic education indicators, for Provinces and the Page 4 of 12 general public to track progress of PROMER II. Sound impact evaluations in selected Provinces would estimate and quantify the effect of Public Disclosure Copy interventions support by the Project. The final design, scope and identification strategy of the proposed evaluations will depend on the agreements reached with the Ministries of Education of the selected Provinces. a. The effects of the teacher training in a selected province. The evaluation would include classroom observations and the development and application of a standardized test as part of the instruments to measure the impact. b. Measuring management practices in a selected province. To measure the impact of training to principals and supervisors, an instrument measuring management practices would be developed and implemented in the Province. c. The effects of strengthening the link between schools and families on dropout and repetition rates in Salta. In an ongoing evaluation, a small fund or grant like the one described in Component 1.2 has been assigned randomly to schools in Salta. The baseline information has been collected and by the end of 2014 the results from the first follow up will be ready. These results will inform on the impact of Component 1.2 of the Project. 4. Project location and salient physical characteristics relevant to the safeguard analysis (if known) Target areas for the envisioned Project’s physical interventions are rural zones. Specific sub-project locations have not been identified; they will be selected during Project implementation. 5. Environmental and Social Safeguards Specialists Lilian Pedersen (LCSSO) Elba Lydia Gaggero (LCSEN) 6. Safeguard Policies Triggered? Explanation (Optional) Public Disclosure Copy Environmental Assessment OP/ Yes Potential physical interventions are foreseen BP 4.01 under Component 2 of the Project. They refer to to i) construction of new schools; and ii) the rehabilitation and refurbishment of schools. The rest of the Project's components would essentially involve institutional development, training, and capacity-building activities. Based on the nature of the works, this Project is classified as Category B, requiring a partial environmental assessment in accordance with the Bank's Safeguards Policies. No major adverse environmental impacts are anticipated for the Project. Expected potential negative impacts would be primarily during the construction phase of small to medium-scale civil works and will be mitigated through specific measures included in the Environmental and Social Management Framework (ESMF) of the Project. Page 5 of 12 Considering that sub-projects would be entirely defined during Project implementation, the Ministry of Education (MEN) has developed an Public Disclosure Copy ESMF according to OP/BP 4.01(Environmental Assessment), that: (i) ensures compliance with pertinent legislation and Bank policies for works of the type considered under the Project; (ii) identifies potential environmental and social impacts based on the scope of physical interventions and site characteristics; (iii) establishes appropriate procedures for sub-project screening as well as mitigation, management, and monitoring measures; and (iv) defines procedures and responsibilities for the environmental and social management of the Project. This also considers specific safety and building standards needed for schools, including structural measures for disaster risk reduction, access for people with disabilities, indoor comfort, etc. As the envisioned works are similar to those that have been executed during the ongoing operation, the proven procedures and measures that are currently being applied, as well as specific improvements, have been incorporated into the ESMF of this new Project. MEN conducted a focus group consultation on Public Disclosure Copy this instrument. The views of consultation participants were incorporated into the ESMF final document. Natural Habitats OP/BP 4.04 Yes Sub-project specific locations would be selected during Project implementation. However, since rural areas are targeted, and moreover, the Project would prioritize locations in dispersed or remote rural areas, it is possible for works to be located in natural habitat zones. Therefore, the environmental Bank’s policy OP/BP 4.04 (Natural Habitats) is triggered for the Project. The corresponding considerations have been included in the ESMF. Forests OP/BP 4.36 No The Project will not support management of forests. Pest Management OP 4.09 No This safeguard does not apply as the Project does not require the purchase, application or storage of pesticides and will not lead to an increased use of pesticides. While the Policy is Page 6 of 12 not triggered, schools may use pesticides during their operational phase to control pests. This aspect would be considered within any efforts to Public Disclosure Copy improve or strengthen MEN’s protocols for school infrastructure management. Physical Cultural Resources OP/ Yes Sub-project specific locations would be selected BP 4.11 during Project implementation. However, since rural areas are targeted, and moreover, the Project would prioritize locations in dispersed or remote rural areas, it is possible for works to be located areas with cultural values (outstanding landscapes, indigenous territories, historic or archaeological heritage sites, etc.). Some school buildings to be rehabilitated may also have cultural values. Then, OP/BP 4.11 is triggered for the Project. The corresponding considerations have been included in the ESMF. Indigenous Peoples OP/BP 4.10 Yes The targeted Project areas are primarily rural, many of which have indigenous communities. Considering that these communities are among the most marginalized in Argentina, OP 4.10 (Indigenous Peoples) is triggered. Based on the results and performance of the first PROMER Project's Indigenous Peoples Plan (IPP) and its responsible institutional parties, a comprehensive social assessment has been carried out and an Indigenous People Planning Framework (IPPF) has been prepared by the MEN, and consulted Public Disclosure Copy with organizations representative of indigenous peoples in order to receive and incorporate their advice and gauge their level of support, to ensure that indigenous peoples are benefiting optimally from the Government education interventions supported by the Project. Involuntary Resettlement OP/BP No Activities under the Project will avoid any 4.12 potential involuntary resettlement impacts and will ensure that if land acquisition is necessary, it will be carried out in a fully voluntary nature. Given that the risk of involuntary resettlement is low, the ESMF willinclude land acquisition screening criteria in order to ensure that any potential involuntary resettlement impacts will be avoided. Safety of Dams OP/BP 4.37 No he Project will not support the construction or rehabilitation of dams nor will it support other Page 7 of 12 investments which rely on the services of existing dams. Therefore, the Policy is not triggered. Projects on International No The Project will not affect international Public Disclosure Copy Waterways OP/BP 7.50 waterways as defined in the Policy. Therefore, this Policy is not triggered. Projects in Disputed Areas OP/BP No The Policy is not triggered because the Project 7.60 will not be implemented in areas known to involve 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: The Project’s physical interventions are foreseen under Component 2, whereby the construction, rehabilitation and refurbishment of schools would be financed. These interventions are of small to medium-sized scale. Thus, no potential large scale, significant and/or irreversible impacts are expected. Anticipated potential adverse environmental impacts would be primarily during the construction phase of civil works (e.g. construction staging, construction activities while school is underway, debris generation, dust emission, noise, safety, and other standard impacts of construction). During the operational stage, potential negative impacts would be related to potential misuse or maintenance problems of the school infrastructure. The prevention, reduction and mitigation of these impacts are mainly based on the adoption of school building design, construction and management good practices, such as the specific measures included in the Environmental and Social Management Framework of the Project. In addition, the Project will support activities linked to providing consistent and sustainable energy (such as stoves in kitchens that do not rely on wood, hereby stalling desertification, especially in Public Disclosure Copy arid climates), harvesting and conserving drinking water, and other rural schools’ infrastructure needs. Off-grid renewable energy for isolated rural areas systems/devices will also be considered, articulating activities with other programs like the PERMER (Secretariat of Energy of Argentina – IBRD). The Project will bring a number of positive social development outcomes and impacts. It will improve basic social services, reduce inequality of opportunity, and enhance human capital accumulation in Argentina’s marginalized rural areas. Specially, the Project will allow increased access to education opportunities for indigenous peoples (teachers and students); greater visibility of indigenous peoples in Project schools; increased access to development opportunities through the local development works; increased access to learning materials for indigenous peoples in their main language; and strengthened social integration through training for indigenous as well as non- indigenous teachers working in rural schools that have indigenous students. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area: No adverse potential indirect and/or long term impacts due to anticipated future activities in the Project area have been identified. The Project will contribute to improving quality of education in Argentina, and facilitating the transition to the labor market for rural Argentine youth. Page 8 of 12 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. N/A Public Disclosure Copy 4. Describe measures taken by the borrower to address safeguard policy issues. Provide an assessment of borrower capacity to plan and implement the measures described. The Project’s institutional and implementation arrangements will build on the arrangements currently in place for the implementation of the Rural Education Improvement Project (PROMER I). The implementing agency is the National Ministry of Education (Ministerio Nacional de Educación, MEN), through its Directorate General for the Unit of International Finance (Dirección General para la Unidad de Financiamiento Internacional, DGUFI). At the national level, the DGUFI would be responsible for coordinating the various activities of the Project, including overseeing execution of activities within each of the participating provinces. Among the key participating entities at the national level are the Infrastructure Directorate (Dirección General de Infraestructura, DI) and, regarding Indigenous People, the Bilingual Intercultural Education Modality (Modalidad de Educación Intercultural Bilingüe, MEIB). At the provincial level, each province has a coordinator responsible for overseeing the implementation of activities. Given that the specific sub-projects will be entirely defined during Project implementation, the MEN has developed an Environmental and Social Management Framework (ESMF), according to OP/BP 4.01 (Environmental Assessment), that: (i) ensures compliance with pertinent legislation and Bank policies for works of the type considered under the Project; (ii) identifies potential environmental and social impacts based on the scope of physical interventions and site characteristics; (iii) establishes appropriate procedures for sub-project screening as well as mitigation, management, and monitoring measures; and (iv) defines procedures and responsibilities for the environmental and social management of the Project. As the envisioned works are similar to those that have been executed during the ongoing operation, the proven procedures and measures that are currently being applied, as well as specific improvements, have been incorporated into the ESMF of this new Project. Public Disclosure Copy Following the ESMF provisions, environmental criteria will be applied along the sub-project cycle. All the works will be screened, designed and implemented in observance of the specific building and safety standards needed for schools, including structural measures for disaster risk reduction, access for people with disabilities, indoor comfort, etc. The ESMF also includes land acquisition screening criteria in order to ensure that any potential involuntary resettlement impacts will be avoided. During works execution, contractors will be required to implement Environmental Technical Specifications established in accordance with the applicable regulatory framework and Bank guidelines, which also cover safety aspects for the school community and construction workers. Upon the completion of works, a Use and Maintenance Manual will be provided to school authorities. Monitoring and reporting procedures are part of the ESMF. The ESMF will be used and implemented by the MEN and the provincial coordination agencies. Activities will be articulated among the different responsible bodies: at the national level DGUFI through the DI; and at the provincial level, the provincial directorates, coordination areas, etc. of the provincial Ministries or its equivalents, designated by the main provincial educational authority. Supervision of works execution would be mainly a responsibility of the provincial level. Specialists of the DI will provide support to provincial teams and perform field audits in the construction work sites and the operational schools. Page 9 of 12 The application of the IPPF will be the responsibility of DGUFI through the Bilingual Intercultural Education Modality (Modalidad de Educación Intercultural Bilingüe – MEIB). Public Disclosure Copy An assessment of the institutional capacity of the implementation agency was carried out during Project preparation. In general, it was found that the teams of specialists within the DI and MEIB are competent to manage safeguards issues. However, some activities are carried out at the provincial level and the improvement of certain mechanisms was identified. In response, the MEN have developed an ESMF that would allow: i) the consolidation of socio-environmental management processes, including articulation among the different levels; and ii) the systematization of monitoring activities and result documentation. In addition, the Project will fund socio-environmental management strengthening activities under its component 3. 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. Key stakeholders are education community representatives, public and private entities that may have interests on rural targeted activities and the Autonomous Educational Indigenous Peoples Council (Consejo Educativo Autónomo de Pueblos Indígenas, CEAPI). The final draft ESMF was disclosed on the MEN website on November 4, 2013. MEN conducted a focus consultation on this instrument with education community representatives (infrastructure areas of all the Provincial Ministries of Education), national environmental authorities/agencies (Directorate of Forest of the Secretariat of Environment and Sustainable Development and the Environmental Unit of the Roads National Directorate), and the NGO Rural Community Network, Red de Comunidades Rurales. The views of consultation participants were incorporated into the final ESMF document, which was disclosed on the MEN website on November 8, 2013 and on the Bank’s Infoshop on November 12, 2013. Based on the principle of free, prior, and informed consultation, Project preparation documents (including Project objectives, approach, activities, mechanisms, and a draft of the Indigenous Public Disclosure Copy People Planning Framework – IPPF were presented to organizations representative of indigenous peoples: the Autonomous Educational Indigenous Peoples Council (Consejo Educativo Autónomo de Pueblos Indígenas, CEAPI). A process of consultations with the organization in order to receive and incorporate their advice and gauge their level of support has been underway, and will continue under implementation. The first consultation took place in September 2013, and the second is scheduled for November 28, 2013. A version of the IPPF incorporating feedback from CEAPI and the Bank was published on the MEN website on November 8, 2013 and on the Bank’s Infoshop on November 12, 2013. B. Disclosure Requirements Environmental Assessment/Audit/Management Plan/Other Date of receipt by the Bank 08-Nov-2013 Date of submission to InfoShop 11-Nov-2013 For category A projects, date of distributing the Executive Summary of the EA to the Executive Directors "In country" Disclosure Argentina 08-Nov-2013 Comments: http://portales.educacion.gov.ar/dgufi/promer/normativa/ Indigenous Peoples Development Plan/Framework Page 10 of 12 Date of receipt by the Bank 08-Nov-2013 Date of submission to InfoShop 08-Nov-2013 "In country" Disclosure Public Disclosure Copy Argentina 08-Nov-2013 Comments: http://portales.educacion.gov.ar/dgufi/promer/normativa/ If the project triggers the Pest Management and/or Physical Cultural Resources policies, the respective issues are to be addressed and disclosed as part of the Environmental Assessment/ Audit/or EMP. If in-country disclosure of any of the above documents is not expected, please explain why: C. Compliance Monitoring Indicators at the Corporate Level OP/BP/GP 4.01 - Environment Assessment Does the project require a stand-alone EA (including EMP) Yes [ ] No [ ] NA [ ] report? If yes, then did the Regional Environment Unit or Sector Yes [ ] No [ ] NA [ ] Manager (SM) review and approve the EA report? Are the cost and the accountabilities for the EMP incorporated Yes [ ] No [ ] NA [ ] in the credit/loan? OP/BP 4.04 - Natural Habitats Would the project result in any significant conversion or Yes [ ] No [ ] NA [ ] degradation of critical natural habitats? If the project would result in significant conversion or Yes [ ] No [ ] NA [ ] degradation of other (non-critical) natural habitats, does the project include mitigation measures acceptable to the Bank? Public Disclosure Copy 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 4.10 - Indigenous Peoples Has a separate Indigenous Peoples Plan/Planning Framework Yes [ ] No [ ] NA [ ] (as appropriate) been prepared in consultation with affected Indigenous Peoples? If yes, then did the Regional unit responsible for safeguards or Yes [ ] No [ ] NA [ ] Sector Manager review the plan? If the whole project is designed to benefit IP, has the design Yes [ ] No [ ] NA [ ] been reviewed and approved by the Regional Social Development Unit or Sector Manager? The World Bank Policy on Disclosure of Information Have relevant safeguard policies documents been sent to the Yes [ ] No [ ] NA [ ] World Bank's Infoshop? Page 11 of 12 Have relevant documents been disclosed in-country in a public Yes [ ] No [ ] NA [ ] place in a form and language that are understandable and Public Disclosure Copy accessible to project-affected groups and local NGOs? All Safeguard Policies Have satisfactory calendar, budget and clear institutional Yes [ ] No [ ] NA [ ] responsibilities been prepared for the implementation of measures related to safeguard policies? Have costs related to safeguard policy measures been included Yes [ ] No [ ] NA [ ] in the project cost? Does the Monitoring and Evaluation system of the project Yes [ ] No [ ] NA [ ] include the monitoring of safeguard impacts and measures related to safeguard policies? 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: Peter Anthony Holland Approved By Sector Manager: Name: Janet K. Entwistle (SM) Date: 18-Nov-2013 Public Disclosure Copy Page 12 of 12