INTEGRATED SAFEGUARDS DATA SHEET ADDITIONAL FINANCING

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1 Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Date ISDS Prepared/Updated: 01-Apr-2014 INTEGRATED SAFEGUARDS DATA SHEET ADDITIONAL FINANCING Date ISDS Approved/Disclosed: 30-Apr-2014 I. BASIC INFORMATION 1. Basic Project Data Report.: ISDSA7742 Country: Ghana Project ID: P Parent Project ID: P Project Name: AF Ghana Social Opportunities Project (P146923) Parent Project Ghana---Social Opportunities Project (P115247) Name: Task Team Suleiman Namara Leader: Estimated Appraisal Date: 21-Mar-2014 Estimated Board Date: 27-May-2014 Managing Unit: AFTSW Lending Instrument: Investment Project Financing Sector(s): Public administration- Agriculture, fishing and forestry (10%), Other social services (80%), Public administration- Other social ser vices (5%), Irrigation and drainage (5%) Theme(s): Social safety nets (10%), Social risk mitigation (70%), Rural services and infrastructure (10%), Rural non-farm income generation (8 %), Natural disaster management (2%) Is this project processed under OP 8.50 (Emergency Recovery) or OP 8.00 (Rapid Response to Crises and Emergencies)? Financing (In USD Million) Total Project Cost: Total Bank Financing: Financing Gap: 0.00 Financing Source Amount BORROWER/RECIPIENT 0.00 International Development Association (IDA) Total Environmental B - Partial Assessment Category: Page 1 of 12

2 Is this a Repeater project? 2. Project Development Objective(s) A. Original Project Development Objectives Parent The objectives of the Project are to improve targeting in social protection spending, increase access to conditional cash transfers nationwide, increase access to employment and cashearning opportunities for the rural poor during the agricultural off-season, and improve economic and social infrastructure in target districts. B. Current Project Development Objectives Parent C. Proposed Project Development Objectives Additional Financing (AF) The Project Development Objectives (PDO) of this Additional Financing is to improve targeting of social protection programs and provide income support to poor households through LEAP grants and LIPW infrastructure in targeted districts. 3. Project Description Proposed project Development Objectives - Additional financing (AF): The revised objective is improve targeting of social protection programs and provide income support to poor households through LEAP grants and LIPW infrastructure in targeted districts. Component One. Social Protection Policy and Systems Strengthening This component builds on the findings of the rationalization study that was funded under component 1 of the original project. This component will have two sub-components: sub-component 1A: Social Protection Policy formulation and sub-component 1B: Social Protection Systems Strengthening. Sub-component 1A: Social Protection Policy Formulation. The objective of this sub-component is to strengthen coordination, financing and implementation of social protection programs through the preparation of a national social protection policy, strategy and an implementation action plan. This sub-component will finance technical assistance, consultations, workshops, and policy dissemination. Policy formulation will be done in consultation with other government agencies involved in Social Protection and donor partners. Additionally, this subcomponent will provide technical assistance to the Ministry of Finance to develop mechanisms within the current budget framework to allocate and monitor social protection spending more efficiently. Analytical work to support social protection budget allocation efficiency will also be supported. The component will further support capacity building for staff of the Ministry of Finance and the National Development Planning Commission to improve understanding and appreciation of social protection issues through trainings, study tours and in country field visits. Sub-component 1B: Social Protection Systems Strengthening. The objective of this sub-component is to support strengthening of social protection systems through the establishment of the Ghana National Household Registry (GNHR). The registry is meant as a tool to improve efficiency, effectiveness, and expand the coverage and scope of social protection interventions in Ghana. This sub-component will finance electronic data collection and processing on households using a Proxy Means Test (PMT) that will be reviewed and updated using the 2013 Page 2 of 12

3 Ghana Living Standards Survey data (GLSS 6) data. This process - the National Targeting System (NTS) - would be used to build the GNHR on poor households eligible for selection by social protection programs. The GNHR would be a database of households, their members, basic living conditions and PMT scores. The GNHR will be used across social protection programs (including LEAP, LIPW, and NHIS) for targeting beneficiaries, thus removing redundancy across programs in the targeting processes. Implementation will be sequenced, starting with the Upper West region in 2014, Upper East Region in 2015 and rthern Region in Geographical maps will be prepared for the rest of the country. It is expected that the roll out will follow these maps. Component Two. Labor Intensive Public Works Implementation and Capacity Building. The objective of this component remains unchanged. The AF will support the scale up of LIPW to reach more beneficiary households. Innovations, particularly to manage oversubscription, improve targeting, and enhance delivery and monitoring of payments will be introduced. The implementation capacity of the local assemblies will continue to be strengthened through capacity building and training. This component will be reorganized under AF with two sub-components: sub-component 2A: Labor Intensive Public Works and sub-component 2B: Capacity Building. Sub-component 2A: Labor Intensive Public works (LIPW). The AF will not only deepen LIPW activities in the existing 49 districts but also scaled up to additional six new districts. The basic design of the LIPW component and menu of sub-projects would be maintained. Selection of new districts will be based on the original poverty formula used under the original project. Labor content of the original project was approximately 50%. The other 50% of the component funds went to contractors and materials. To maximize labor content under AF, the breakdown of sub-projects would be 20% for feeder roads, 30% for climate change activities and 50% for small earth dams and dugouts. To manage oversubscription, the AF activities would support: (i) improved planning to enable site managers to take into account a realistic number of work days and tools that are available per cycle; and (ii) in addition to self-targeting, use communitybased targeting (CBT) to further narrow down the eligible beneficiary pool; (iii) the computerization of time sheets to enable faster processing of payroll information as well as introduction of an electronic payment mechanism to improve efficiency. For sustainability, income generating activities financed under a US$ 3million Japanese Social Development Grant will complement LIPW activities. The project will continue to use qualified contractors to ensure that small earth dams and dugouts are prepared in strict conformity with standard designs and specifications. Details on quality improvements for sub-projects will be detailed in the revised Operational Manual. Sub-component 2B: Capacity Building for LIPW. The original capacity building component was implemented by the MLGRD but some activities supported by the MoGCSP. Under AF, this component has been restructured to enable each of the implementing Ministries implement their own capacity building activities. This sub-component will finance capacity building activities for implementation of LIPW in selected project districts. Several distinct sets of capacity building activities under the original project will continue to be supported under AF, specifically: (i) establishing a LIPW supportive policy and institutional framework; (ii) capacity building to support LIPW implementation aimed at decision-makers, DA technical staff, relevant line agencies, and contractors; and (iii) ongoing capacity building for DAs in the technical and management capacities of LIPW target districts. In addition, this sub-component will support the implementation of social accountability and grievance redress mechanisms, development communication activities, capacity building for the introduction of ICT-based operational enhancements (such as electronic registration and electronic timesheets linked to e-payments), impact evaluation, and other activities to support the overall objective of strengthening LIPW. Page 3 of 12

4 Component Three. Livelihood Empowerment Against Poverty (LEAP) Implementation and Capacity Building. This component will be restructured under AF to have two sub-components: sub-component 2A: LEAP Grants and sub-component 2B: Capacity Building for LEAP Sub-component 3A: LEAP Grants The objective of this sub-component is to support the scale up of the LEAP grants to benefit more households. Under the original project, the LEAP grants were meant to be conditional, the PAD was not clear whether these were hard or soft conditions. In practice, soft conditions have been implemented. Beneficiaries are sensitized about sending children ages 5-15 to school, and ensuring regular clinical visits and full immunizations for all children in beneficiary households. The implementation of these soft conditions needs to be better structured through regular workshops under additional financing. The AF will continue to finance cash grants to additional beneficiary households. Broadly, the government has increased its allocation to LEAP from GHc 7.5 million in 2010 to GHc 38 million in Going forward, the financing of this component will be restructured to utilize regular project investment financing modalities, with periodic payments made directly to the MoGCSP for the LEAP cash grants. Sub-component 3b: Capacity Building for LEAP In order to enhance LEAP implementation, this sub-component would provide financing to strengthen the program s operations at the national, regional and district levels. Specifically, the subcomponent would finance the development of a Management Information System for the program (to be coordinated with the GHR) that will support data entry and analysis at the national and decentralized levels, delivery charges associated with the new electronic payments mechanism, and training and capacity building of staff to implement LEAP more effectively. This sub-component would provide funding for development communication activities, as well as monitoring and evaluation (i.e. regular spot checks of operation activities and impact evaluation studies), and social accountability and grievance redress systems for the program. In addition, the sub-component would also ensure and support the improved implementation of soft conditions through structured workshops, regular and documented dissemination fora for LEAP beneficiaries. Component Four. Project Management and Coordination. The objective of this component remains unchanged. Overall project implementation will be undertaken by the Ministry of Local Government and Rural Development (Components 2 and 4A) and the Ministry of Gender Children and Social Protection (Components 1, 3 and 4B). The Chief Directors of the two ministries will maintain overall financial responsibility of project funds. Policy implementation guidance will be provided by a project steering committee that will be chaired by the Honorable Minister of Gender, Children and Social Protection and co-chaired by the Honorable Minister of Local Government and Rural Development. The committee will comprise of relevant ministries, departments and agencies of the government and civil society organizations (a full list is elaborated in Annex 4 under revised implementation arrangements and support). The steering committee will approve annual work plans, budgets, quarterly and annual progress reports and mobilize government support (further details are elaborated in the Project Operational Manual). The committee will also be staffed by 1 technical staff who will consolidate project quarterly and annual reports for steering committee review and approval, before submission to the relevant accounting officers of the two ministries and the Bank. Under the AF, this component will be restructured into two sub-components to reflect the addition of Page 4 of 12

5 the MoGCSP as an independent implementing agency: sub-component 4A: Project management and coordination by the Ministry of Local Government and Rural Development, and sub-component 4B: Project management and coordination by the Ministry of Gender, Children and Social Protection. Sub-component 4A: Project management and coordination by the Ministry of Local Government and Rural Development. The objective of this sub-component is to support activities related to project management and coordination, equipment and vehicles, and incremental operating costs under the GSOP National Coordination Office and Regional Coordination Officers for LIPW sub-projects. Sub-component 4B: Project management and coordination by the Ministry of Gender, Children and Social Protection. The objective of this sub-component is to support activities related to project management and coordination, equipment and vehicles, and incremental operating costs under the MoGCSP. 4. Project location and salient physical characteristics relevant to the safeguard analysis (if known) The existing parent project was started in 49 districts within three of the administrative regions in the rthern Savannah Zone: Upper East Region, Upper West Region, and rthern Region and later extended to cover 20 districts in the Ashanti, Brong-Ahafo, Central, Eastern, Greater Accra, Volta and Western Regions which lie within transitional, high forest zones and coastal grasslands. The project has several hundred community level small scale sub-projects, predominantly in rural areas, situated typically on communal lands. The Additional financing will enable a geographical scaling of the same subproject activities to cover an additional 6 districts for a total of 55 District Assemblies within the existing regions. The overall safeguard analysis from the parent project will not experience a significant change because the geographical characteristics of the receptor susceptibilities within the regions will not change. 5. Environmental and Social Safeguards Specialists Martin Fodor (AFTN3) Franklin Kuma Kwasi Gavu (AFTN3) Felix Nii Tettey Oku (AFTN3) 6. Safeguard Policies Triggered? Explanation (Optional) Environmental Assessment OP/ BP 4.01 Natural Habitats OP/BP 4.04 Yes The project triggers OP4.01 due to the planned construction activities. The LIPW component of the project involves renovation and construction activities which could have an adverse impact on the general environment. An ESMF and RPF has been prepared to address potential environmental/ social impacts associated with the demand driven sub-projects and mitigation measures related to the project activities. Forests OP/BP 4.36 Page 5 of 12

6 Pest Management OP 4.09 Physical Cultural Resources OP/ BP 4.11 Indigenous Peoples OP/BP 4.10 Involuntary Resettlement OP/BP 4.12 Yes The project may require pieces of land as part of the rehabilitation of rural roads and community infrastructure. The proposed activities are not expected to trigger the involuntary resettlement. netheless, the project has developed an RPF which will guide the implementation of its activities. The RPF will be use d to guide the process of land acquisition and provision of the appropriate compensations to affected individuals, if applicable. Safety of Dams OP/BP 4.37 Yes The LIPW component of the project will involve renovation of existing small earth dams and dugouts which could have adverse impact on the general environment. The Additional Financing will finance the rehabilitation of small earth dams and dugout of mainly 5-6m high. A Dam Safety Plan has been developed to ensure safety of the small earth dams and dugouts during and after rehabilitation. The dam safety plan describes the types of small earth dams and dugouts to be rehabilitated and their size and storage capacity. According to the plan, the rehabilitated small earth dams may exceed 500m in length because of the flat topography of the north, but the project will pre-select small earth dams where the storage capacity does not exceed 250,000m3 for a 5m dam. The project will ensure that capacity does not exceed 500,000m3 for a 6m high small earth dam; and that selected small earth dams are generally not located near settlement areas. Only feasibility studies will be undertaken for small earth dams of heights 6-10m high. There was a general low technical capacity regarding local designers, contractors and supervisors to monitor and ensure the sound construction of small earth dams and dugouts in Ghana. To mitigate these concerns, the project has provided on the job training for workers, Ghana Irrigation Development Authority (GIDA) staff and others associated with the rehabilitation and Page 6 of 12

7 Projects on International Waterways OP/BP 7.50 Projects in Disputed Areas OP/BP 7.60 Yes maintenance of the small earth dams and dugouts. Water/Dam users associations have also been used to perform regular dam maintenance and consistent monitoring throughout the project period; this mechanism will continue to be supported by the project. External expertise will be used where necessary and the ESMF will be used to ensure adequate and responsive mitigation measures are applied. OP/BP 7.50 was triggered because the project involved renovation of between small earth dams and dugouts on tributaries of an international waterway (Black and White Volta) An exemption for the riparian notification was granted for the project on the following basis: (i) the engineering findings confirmed that the incremental water use would be insignificant; (ii) the rehabilitation works are to be located in tributaries of an international waterway where these tributaries run exclusively in one state and the state is the lowest downstream riparian. 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: Environment: Potential impacts (minimal and localized) from subprojects such as dust emission, noise and vibration, burrow pits, generation of construction waste, small earth dam and dugout failures, siltation and modification of flowing waters and health & safety of workers and general public have been readily avoided, minimized and/or mitigated through measures which included minimizing ground clearance, redesign of roads to ensure flood prevention, provision of settling basins to remove silt and debris before discharge to streams, provision of buffer zones of undisturbed vegetation between construction sites and water bodies and re-vegetation of dam banks. The climate change subprojects have provided positive environmental impacts through afforestation of otherwise degraded lands within the beneficiary communities and this positive impact will be sustained under the additional financing. significant and/or irreversible impacts are anticipated with any of the associated subproject works. The Additional Financing will finance the rehabilitation of small earth dams and dugout of mainly 3-6m high. A Dam Safety Plan has been developed to ensure safety of the small earth dams and dugouts during and after rehabilitation. The dam safety plan describes the types of small earth dams and dugouts to be rehabilitated and their size and storage capacity. There was a general low technical capacity regarding local designers, contractors and supervisors to monitor and ensure the sound construction of small earth dams and dugouts within the beneficiary District Assemblies during parent project inception. Safeguard management trainings have been given to key project Page 7 of 12

8 implementing staff since project inception. Water/Dam users associations have also been used to perform regular dam maintenance and consistent monitoring throughout the project period; this mechanism will continue to be supported by the project. External expertise will be used where necessary. Social: The potential social and resettlement impacts that may arise as a result of the sub-projects include the loss of agricultural lands, residential buildings and structures, livelihood (business premises and structures), non-productive fruit and shade trees, access to resources such as grazing land, and economic trees such as shea-butter trees. The choice of Sub-projects however will first seek to avoid or minimize involuntary resettlement or land acquisition as much as possible. twithstanding the minimal social impacts from the sub-projects the Government of Ghana has prepared a Resettlement Policy Framework (RPF) with the purpose of clarifying applicable resettlement principles, organizational arrangements and design criteria. The objectives of the RPF are consistent with avoiding or minimizing involuntary resettlement or land acquisition where possible; where unavoidable, ensuring that compensation and resettlement are designed and implemented with sustainability as the prime focus; and ensuring that affected persons are supported to improve their livelihood or at least restore them to pre-displacement levels. The RPF sets out the legal and administrative framework, which includes the systems of land ownership and tenure as well as the socio-economic characteristics of beneficiary districts. It also details the consultation processes, eligibility criteria, and methodology for valuation of assets and a clear entitlement policy and compensation payment processes. In order to ensure that implementation of the RPF is on course and accountability aligned, the RFP has articulated monitoring and evaluation with clear delineations of monitoring indicators and the responsibilities of agencies. The RPF outlined sections on organizational arrangements for implementation and monitoring and a template for the design of a resettlement action plan should that become necessary after identification of exact project sites or locations. The project will prepare a resettlement action plan or an abbreviated resettlement action plan (given the number of affected people) if land-seizure, displacement, or resettlement occurs or when people s livelihoods are affected due to limited access to assets or source of livelihood during implementation. The RPF outlines measures for building the capacity of officials responsible for implementing the RPF. The additional financing will not trigger any new safeguard policies since it involves the same scope of subproject works within similar geographical locations of the parent project. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area: potential indirect and/or long-term environmental and social impacts due to future activities in the project area are anticipated due to small scale, distributed nature of the sub-projects. 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. The alternative of not including renovation of existing small earth dams and dugouts under the LIPW component of GSOP was given a serious consideration during the preparation of the parent project in It was thought the local people to be recruited for the works lacked the skills to Page 8 of 12

9 mitigate the potential risks associated works. However, given that these small earth dams and dugouts are the life-line of people in the beneficiary regions and the Bank s overall mission is poverty reduction, it was deemed worthwhile to invest in the small earth dams and dugouts if the risks could be mitigated effectively. A number of dam engineers were therefore brought into the project to make the assessment of the small earth dams and dugouts to be rehabilitated and it was determined that the risks were minimal given the height and scale of these small earth dams. The environmental categorization for the project remains unchanged (Classified as Category B given that that associated subproject works are unlikely to lead to significant adverse environment impacts). A dam safety plan has been prepared and implemented since project inception and about one hundred and twenty five (125) small earth dams and dugouts have been renovated so far without any significant environmental concerns. This additional financing will continue to fund the rehabilitation of such small earth dams and dugouts. Participatory planning will be used to assess the siting of constructional works under the LIPW components to ensure minimal environment social impact and maximum communal benefits. 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 Government of Ghana prepared an Environmental and Social Management Framework (ESMF), a Resettlement Policy Framework (RPF), and a Dam safety plan in compliance with the triggered policies. An exemption for the riparian notification was granted for the project on the following basis: (i) the engineering findings confirmed that the incremental water use would be insignificant; (ii) the rehabilitation works are to be located in tributaries of an international waterway where these tributaries run exclusively in one state and the state is the lowest downstream riparian. The additional financing will not trigger any new safeguard policies since it involves the same scope of subproject works within similar geographical locations (geographical up scaling) to that of the parent project. Therefore the existing safeguard due diligence frameworks (ESMF, RPF and Dam Safety Plan) for the parent GSOP will be implemented for the proposed Additional Financing. The Ministry of Local Government and Rural Development (MLGRD) has overall responsibility for the project, but the implementation of the component activities will be handled by different agencies, including District Assemblies (DAs) and the National Disaster Management Organization (NADMO). The implementation of the Community-Based Rural Development Project (CBRDP) has given the MLGRD a level of capacity in safeguards as per World Bank policy requirements which has been sustained under the GSOP operation. Under the CBRDP and in collaboration with the Environmental Protection Agency (EPA) of Ghana, the MLGRD developed a manual to train selected District Assembly officials while processing the environmental impact assessment for sub-projects at the community level. This combination of an agency well-versed in national and World Bank safeguard policies and requirements (i.e. EPA- Ghana) and ministries with on-the ground experience in projects similar to the SOP has fostered a solid working relationship since project inception. The ESMF and RPF have identified capacity-building activities for the various key stakeholders to ensure understanding of safeguards and application of implementation and monitoring measures to achieve sustainability and to avoid or reduce negative impacts. For both the RPF and ESMF, a budget estimate for the required training and capacity building has been included. Since the inception of the parent project in 2010, various trainings sessions have been offered to key stakeholders to help with the implementation of the ESMP. At the District Assembly level, GIDA key staff and DA works department s engineers have been trained under an ILO/GSOP Technical Page 9 of 12

10 Assistance. Site supervisors of contractors have also been trained on safeguard issues. The GSOP regional engineers have also been trained to offer backup support. Currently it is a pre-contractual requirement for contractors to receive training and certification in safeguard awareness training through the ILO/GSOP before LIPW renovation works contracts are awarded. As part of the project implementation and supervision, the Bank team has visited sampled project sites. The objective of the site visits was to assess effectiveness of implementation of safeguard due diligence since project inception. The sites visited included those with subproject works on small earth dam/dugouts, climate change (afforestation), feeder roads construction and socio economic infrastructure (schools). It was noted during the visit that the project has demonstrated good environmental and social practice. All the sampled sub-projects have been screened (copies inspected at both the GSOP regional office and at beneficiary District Assembly) as per requirements of the ESMF to assess potential environmental and social impacts. Screening, registration with the National Environmental Protection Agency (EPA) and issuance of permits (where required) have also been undertaken for the sampled subprojects (copies of the sampled subprojects were inspected at both the regional GSOP and EPA offices). Consultation/disclosure requirements with beneficiary communities have been met via EPA and ESMF screening processes for all the sampled subprojects. Field observations showed renovation works on the feeder roads, dugouts and small earth dams were minor and localized which pose no or minimal environmental risks (constructional and operational) to potential receptors within their immediate environs. The renovation works have strengthened the overall stability of the existing dugouts through the placement of ripraps, compaction of locally derived earth material (at optimum moisture content) on the surfaces of existing embankments (up and downstream). The construction works were undertaken by contractor supervisors who have hitherto received prior training and certification by experienced engineers from the Ghana Irrigation Development Authority (GIDA). Additionally a dam safety manual is in place to address potential dam safety risks. A progress status report has been prepared as an addendum to the ESMF to assess the effectiveness of the existing mitigation measures. The report shows an overall satisfactory rating for both performance and compliance of the existing environmental management plan. The Government of Ghana will use the mitigation measures within the existing safeguard instruments (ESMF and RPF) for the continuous management of the potential impacts from the sub project works under the Additional financing. 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. During the preparation of the parent project's ESMF and RPF, there was extensive consultation with stakeholders at community, district and the national level. The stakeholders included the project beneficiaries (who are mostly poor and vulnerable), staff of the CBRDP at the national level, District Assembly officials, and community opinion leaders, including chiefs and ordinary citizens. The process for preparing these safeguards documents requires consultations and information disclosure. The required disclosures were completed in-country and at the World Bank s Infoshop respectively on 04/14/2010, 04/13/2010 for the ESMF and 02/10/10, 02/11/10. Consultations were undertaken within representative district assemblies (rthern Region- East Gonja District, Upper East Region - Nabdam District, Central Region-Assin South District, Upper West -Jirapa District, Ashanti Region- Sekyere Kumawu District) within the proposed areas for the additional financing from February 10-12, 2014 as done prior to appraisal of the parent project. Page 10 of 12

11 The objective of the consultations was to involve and sensitize project beneficiaries, solicit their views and inputs, and identify potential impacts and gauge their understanding of the ESMF. The consultations involved group discussions with a number of people, including women and children, and interviews with local institutional heads like District Assembly officials and NGOs. Overall, the project has been overwhelmingly viewed as beneficial to the poor, vulnerable and socially disadvantaged in the community. Additionally, the design of the parent project was heavily informed by a Participatory Poverty and Vulnerability Assessment (PPVA), supported by DFID, UNICEF, and the World Bank, which was commissioned to inform the design of poverty reduction policies in Ghana with a focus on the rthern Savannah and other related regions. Results of two rounds of PPVA fieldwork was integrated into the project design. Both rounds of work were carried out in twelve communities in northern Ghana: three in the rthern Region, three in the Upper West Region, and six in the Upper East Region. The PPVA also undertook fieldwork in five communities in the south of Ghana, with a focus on northern migrants working outside of their home area. B. Disclosure Requirements Environmental Assessment/Audit/Management Plan/Other Date of receipt by the Bank Date of submission to InfoShop For category A projects, date of distributing the Executive Summary of the EA to the Executive Directors "In country" Disclosure Ghana Comments: Resettlement Action Plan/Framework/Policy Process Date of receipt by the Bank Date of submission to InfoShop "In country" Disclosure 20-Feb Mar Mar Feb Mar-2014 Comments: If the project triggers the Pest Management and/or Physical Cultural Resources policies, the respective issues are to be addressed and disclosed as part of the Environmental Assessment/ Audit/or EMP. If in-country disclosure of any of the above documents is not expected, please explain why: C. Compliance Monitoring Indicators at the Corporate Level OP/BP/GP Environment Assessment Does the project require a stand-alone EA (including EMP) report? OP/BP Involuntary Resettlement Has a resettlement plan/abbreviated plan/policy framework/ process framework (as appropriate) been prepared? Yes [ ] [ ] NA [ ] Yes [ ] [ ] NA [ ] Page 11 of 12

12 If yes, then did the Regional unit responsible for safeguards or Yes [ ] [ ] NA [ ] Sector Manager review the plan? OP/BP Safety of Dams Have dam safety plans been prepared? Yes [ ] [ ] NA [ ] Have the TORs as well as composition for the independent Panel of Experts (POE) been reviewed and approved by the Bank? Yes [ ] [ ] NA [ ] Has an Emergency Preparedness Plan (EPP) been prepared and Yes [ ] [ ] NA [ ] arrangements been made for public awareness and training? OP Projects on International Waterways Have the other riparians been notified of the project? Yes [ ] [ ] NA [ ] If the project falls under one of the exceptions to the Yes [ ] [ ] NA [ ] notification requirement, has this been cleared with the Legal Department, and the memo to the RVP prepared and sent? Has the RVP approved such an exception? Yes [ ] [ ] NA [ ] The World Bank Policy on Disclosure of Information Have relevant safeguard policies documents been sent to the Yes [ ] [ ] NA [ ] World Bank's Infoshop? Have relevant documents been disclosed in-country in a public Yes [ ] [ ] 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 [ ] [ ] NA [ ] responsibilities been prepared for the implementation of measures related to safeguard policies? Have costs related to safeguard policy measures been included Yes [ ] [ ] NA [ ] in the project cost? Does the Monitoring and Evaluation system of the project Yes [ ] [ ] NA [ ] include the monitoring of safeguard impacts and measures related to safeguard policies? Have satisfactory implementation arrangements been agreed with the borrower and the same been adequately reflected in the project legal documents? Yes [ ] [ ] NA [ ] III. APPROVALS Task Team Leader: Name: Suleiman Namara Approved By Regional Safeguards Name: Alexandra C. Bezeredi (RSA) Date: 01-Apr-2014 Advisor: Sector Manager: Name: Stefano Paternostro (SM) Date: 30-Apr-2014 Page 12 of 12