IDA Amount ($m): Managing Unit: ECSIE

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1 Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Integrated Safeguards Data Sheet (Updated) Report No: AC570 Section I - Basic Information Date Prepared/Updated: 01/15/2004 A. Basic Project Data (from PDS) I.A.1. Project Statistics Country: CROATIA Project ID: P Project: COASTAL CITIES POLLUTION CONTROL Task Team Leader: Manuel G. Marino PROJECT Authorized to Appraise Date: March 9, 2004 IBRD Amount ($m): Bank Approval: May 18, 2004 IDA Amount ($m): Managing Unit: ECSIE Sector: Sewerage (70%); General water, sanitation Lending Instrument: Adaptable Program Loan (APL) and flood protection sector (30%) Status: Lending Theme: Pollution management and environmental health (P); Other environment and natural resources management (P) I.A.2. Project Objectives (From PDS): The overall Project Development Objective is to improve the quality of Croatia's Adriatic coastal waters to meet European Union (EU) ambient quality standards in the participating municipalities, in a financially and operationally sustainable manner, through (i) support for the strengthening of the institutional arrangements for financing and management of wastewater management in Croatia and (ii) financing of wastewater collection, treatment and disposal infrastructure in selected coastal municipalities. The Project will also provide technical assistance and financing for engineering services, improvements in the environmental monitoring system for the assessments of Project results and support of Project implementation. The Government has selected the Adaptable Program Lending (APL) approach for the sector, rather than addressing investment needs city-by-city and project-by-project. The sector policy issues, under the overall objective of complying with the environmental "acquis communautaire", are basically identical throughout Croatia's urban areas and the model for addressing them was established with the Municipal Environmental Infrastructure Project (MEIP). The work carried out during Project preparation has resulted in a comprehensive "Coastal Cities Pollution Control Program" (the Program) approved by the Government on March 2003 and on the adoption of the Program's Operational Manual. This Manual covers all aspects of Program implementation, from appraisal methodology to the procedures to mainstream social and environmental safeguard policies. The Government's strategy is to initiate the Program in larger urban areas not yet served with adequate wastewater management infrastructure, and to expand horizontally, and if necessary vertically, in a programmatic manner. Additionally, the Government has established an environmental regional onlending mechanism for this Program through the creation of a Special Purpose -Subsidiary Company (SPSC) of Hrvatske Vode (HV), which will be in charge and responsible of the implementation of the Program. An APL approach will provide a framework for planning and implementing the medium-term investment program needed to comply with requirements for EU accession by helping HV, through the SPSC, to take a phased approach to planning and identifying funding sources, while building the necessary regulatory, monitoring, and control capacity. Individual investment subprojects in each Municipal Water and Sewerage Company (MWSC), as has been the case until now, would have made such planning more difficult to conceptualize and implement, and a "projectized" approach would have been less efficient from

2 2 a management perspective. Thus, an APL, with triggers designed to deepen the sectors financial, regulatory and management policies and practices, was the logical choice for the next intervention. In order to acknowledge the speed with which the Government and urban utilities can implement the envisaged measures and adapt and refine the implementation procedures and safeguards, the APL is designed in three Phases. Phase I eligibility criteria concentrate on developing the financing framework and achieving operational autonomy and financial stability in participating MWSCs through the adoption of adequate tariff structures and levels and appropriate investment scope, while proceeding to Phase II requires that (i) adequate monitoring and control capacity is in place; (ii) Phase I investments have been efficiently implemented; (iii) policy reforms in line with the objective of complying with the relevant environmental "acquis communautaire " have been adopted; and (iv) relevant sector institutions have demonstrated their ability to implement the Program and extend its coverage to the rest of the coastal areas. I.A.3. Project Description (From PDS): To support the Government's Program, the first phase of the APL will comprise a sector investment loan using the Government's Environmental Infrastructure Financing Facility (EIFF), to be implemented through HV's SPSC, to finance wastewater treatment and discharge infrastructure, sewerage expansion and technical assistance, with SPSC acting as technical implementing agency. HV will facilitate subproject preparation and implementation and coordinate funding requests to the Bank and other sources. The SPSC would have overall technical responsibility for Project implementation (including procurement) and specific financial responsibilities for investments in infrastructure for wastewater treatment and discharge, while MWSCs would have financial responsibility for investments in sewerage expansion. The attached maps identify the municipalities that have been identified as candidates to participate in the Project and in the overall Program and present subproject engineering and technical designs for the systems of the municipalities of Krk, Opatija, Biograd and Zadar. These have been identified as candidates for the first year of Project implementation and appraised as part of Project preparation. Overall investments for Phase I have been estimated on the basis of the investment proposed for these municipalities' wastewater management systems and for those in the municipalities of Orebic, Korcula, Vela Luka, Trpanj, Rijeka, Makarska, and Ston. Consistent with the scope and objectives identified above, the Project would have three components: 1. Coastal Environmental Infrastructure Component ($64.80 million for Phase I of the APL), to finance. * Investments in the construction/expansion of sewerage networks; and * Investments in main collectors, pumping stations, wastewater treatment plants and submarine outfalls. The financing of investment would be based on the following principles: a) Wastewater treatment and disposal facilities would be financed by HV through the SPSC, using a combination of credit, resources from the Water Fund, specific Project surcharges, and targeted subsidies from Government budgetary transfers. b) Sewerage and related infrastructure will be financed by a combination of municipal sources, credit, Project surcharges and potential contributions, as direct subsidies, from HV and/or the Central

3 3 Government. As discussed above, the operation is being prepared within a dynamic institutional setting. The Government is revising the role of HV, consolidating it as the agency responsible for wastewater treatment facilities throughout Croatia. The financing mechanism 'for the Project would reflect the success of the ongoing Bank-financed operations (namely the MEIP in Split and the Eastern Slavonia Reconstruction Project), and at the same time the aims to advance on the policy agenda for developing sustainable sub-national credit facilities in Croatia. As in the Slavonia Project, the Ministry of Finance would be the Project's borrower. Project funds will be on-lent to establish the EIFF within the SPSC, which will on-lend part of these funds to municipal (or regional) water and sewerage companies. Under the proposed Project, the approach would build upon HV's experience to handle the financial management of the on-lending activities with the support of the Bank, which will appraise all subprojects on an annual basis. All procedures for subproject preparation and the criteria for subproject appraisal have been defined ex-ante and included in the Program's Operational Manual, which the Bank has reviewed and found to be satisfactory. Detailed engineering and technical designs for the first year of the Project, including environmental and social assessments, financial models, and tariff schedules agreed-upon with municipal officials, have been completed prior to loan appraisal. In addition to an annual appraisal of the work program during Project supervision, the guiding principles for subproject evaluation and eligibility include: a) A financial analysis, taking into account all sources of financing (project and HV surcharges, direct Government subsidies, and tariff revenues) demonstrating that funds will be sufficient to cover Operation and Maintenance (O&M) costs, loan repayment, and depreciation. b) Location permits. Location permits are required by Law in Croatia before any public work can be executed. In order to obtain a location permit the developer has to produce an Environmental Impact Assessment (EA) approved by the Ministry of Environmental Protection and Physical Planning (MoE). Compliance with this requirement is a condition of eligibility for all subprojects in subsequent years. c) Construction Permits. Following the granting of Location Permits, Construction Permits are also required by Law in Croatia. One of the requirements for getting Construction Permits is the approval of the main design, which has to include proof of ownership and/or land usage permission. d) A least-cost analysis for each subproject, reviewing all options considered for achieving EU quality standards in bathing and shellfish growing waters in the vicinity of the affected areas. e) Priority in terms of receiving water quality. Region-wide criteria developed during Project preparation define clear investment objectives and, based on these objectives, the Government has adopted a prioritized plan that ranks wastewater treatment investments in terms of their cost effectiveness and sensitivity of receiving waters. f) Utility preparedness in terms of its ability to contribute to capital cost, management and operation capacity and financial viability. In this context, an assessment of water supply and sewerage operations is also included to ensure that they meet reasonable efficiency standards.

4 4 2. Institutional Strengthening and Program Management Component ($4.69 million for Phase I of the APL), to finance equipment, technical assistance, training and studies to: * Devise and implement an institutional framework for water pollution control; * Complete engineering designs and environmental and social assessments for investments after the first year of the Program and supervise Project investments; * Ensure the capacity of the SPSC for Project implementation, evaluation and monitoring, including financial management; and * Strengthen and bring utilities to reasonable levels of management, operational efficiency and financial viability and potentially facilitate private sector participation. Technical assistance for the strengthening of municipal water utilities would be provided on a grant basis by HV through the SPSC. 3. Strengthening of the Coastal Waters Monitoring Network ($8.75 million for phase I of the APL) to finance equipment, civil works and technical assistance (see Annex 12 of the Project Appraisal Document (PAD) for details on the existing capacity and programs and on the proposed approach) to: * Improve the capacity of the MoE network of laboratories for environmental monitoring to assess the impact of the Program on coastal waters quality * Improve the capacity of HV's laboratories to assess the individual discharges of municipalities and industries, determine the overall pollutants load contributed by Croatia to the Adriatic sea and evaluate and control the efficiency of the financed infrastructure * Provide decision-makers with a critical and reliable environmental monitoring tool allowing to measure compliance of Croatian coastal waters with relevant EU standards and to adjust the level of wastewater treatment to reach compliance through targeted and phased investments. The first part of this Component, to be implemented by MoE, would be financed on a grant basis from Government funds and loan proceeds, through direct budgetary transfers from the Ministry of Finance. The second part of the Component would be implemented by the SPSC on behalf of HV. Main Project costs for the APL Phase I are summarized in the attached table below. Components: 1. Coastal Environmental Infrastructure Component a) Sewerage extension and rehabilitation b) Wastewater treatment and disposal infrastructure 2. Institutional Strengthening and Program Management Component 3. Strengthening of the Coastal Waters Monitoring Network a) Strengthening of the Environmental Monitoring Network b) Strengthening of the Wastewater Discharge Control Network Contingencies I.A.4. Project Location: (Geographic location, information about the key enviromnental and social characteristics of the area and population likely to be affected, and proximity to any protected areas, or sites or critical natural habitats, or any other culturally or socially sensitive areas.) The project will be located in Croatia's Adriatic coast. It will include both mainland and island sites. By design, no subproject sites will be located in the proximity of any protected areas or sites of critical natural habitats, as has been confirmed during the EA, at which time the possible existence of culturally or

5 5 socially sensitivity areas have been assessed. B. Check Environmental Classification: F (Financial Intermediary Assessment) Comments: By appraisal, selected subprojects identified for the first year of project implementation will be confirmed, based on the satisfactory completion of required documents, including EA, SA, etc. The EAs, SAs, Resettlement and Acquisition Policy and environment section of operational manual have been disclosed in country and in Infoshop prior to project appraisal departure. C. Safeguard Policies Triggered (from PDS) (click on Q for a detailed desciption or click on the policy number for a brief description) F- Policy Triggered Environmental Assessment (OP 4.01, BP 4.01, GP 4.01) Natural Habitats (OP 4.04, BP 4.04, GP 4.04) Forestry (OP 4.36, GP 4.36) Pest Management (OP 4.09) 0 Yes * No Cultural Property (OPN 11.03) Indigenous Peoples (OD 4.20) Involuntary Resettlement (OP/BP 4.12) Safety of Dams (OP 4.37, BP 4.37) Projects in International Waters (OP 7.50, BP 7.50, GP 7.50) * Yes 0 No Projects in Disputed Areas (OP 7.60, BP 7.60, GP 7.60)* Section H - Key Safeguard Issues and Their Management D. Summary of Key Safeguard Issues. Please fill in all relevant questions. If information is not available, describe steps to be taken to obtain necessary data. II.D.la. Describe any safeguard issues and impacts associated with the proposed project. Identify and describe any potential large scale, significant and/or irreversible impacts. General Impacts The Project will have substantial environmental benefits with a direct impact on the populations of the Project area, which counts approximately 300,000 permanent residents in the coastal region (in the participating municipalities) as well as seasonal tourists which increases population to 850,000 in the summer months. By focusing on this region, the Project aims to have an important impact on preserving the environmental resources on which tourism growth and its capacity for employment generation is based. Major investment in infrastructure in priority areas and "hotspots" would help to both improve water quality in key areas and to develop replicable models for sector development. Investing in wastewater treatment is expected to have a direct and positive impact on improving and maintaining the quality of bathing and fishing waters. The associated economic benefits are expected to be significant, and meeting the EU water quality requirements for accession is an articulated policy goal of the Government. In addition, Program investments are expected to have positive effects on the viability of the fisheries and aquaculture sectors, and detailed investment design will take into account the impact on local fisheries and areas of shellfish cultivation.

6 6 The project triggers four safeguards: environmental assessment; projects in international waters, cultural property and involuntary resettlement (land acquisition). None of them pose special risks, as they are, and will be, managed systematically, using local experience and local standards that are acceptable to the Bank. All safeguard policies triggered by the project can be adequately dealt with given the good practice in Croatia and the institutional capacity to enforce it. Environmental Impacts: The Project is expected to have positive environmental impacts which relate to: (i) improvements in public health through better water quality of bathing and shellfish growing areas; (ii) enhanced environmental conditions as a result of more reliable wastewater treatment; and (iii) increased viability of the fisheries and aquaculture sectors. Potential negative impacts generally associated with wastewater projects will be adressed for each subproject, as part of the EA, through an Environmental Management Plan (EMP). In particular, potential negative impacts generally associated with wastewater projects are: * Impacts due to construction practices, e.g. noise, dust * Degradation of sensitive aquatic environment due to discharge of wastewater * Degradation of neighborhoods or receiving water quality from sewer overflows, treatment works bypasses, or treatment process failures * Public health hazards in the vicinity of discharges * Odors, noise and emission of volatile organics from treatment processes * Sludge disposal issues * Accidental destruction of cultural heritage sites. In addition, due to the nature of the Project, the EMPs will give special attention to the impact on receiving waters of the proposed discharge infrastructure and to the arrangements for the proper disposal of sludge and solid waste residues that might be produced in the treatment process. Potential negative impacts of the Project will be addressed by prevention or mitigation measures. Additionally, the EMPs will detail the environmental monitoring program requirements. Project Component III, Strengthening of Environmental Monitoring Networks, will support HV and the MoE in improving the coverage, reliability and accuracy of the monitoring networks currently operating. Project social development outcomes and summary of key social issues relevant to projet objectives The principal social development outcomes of the Project are improved health and sanitary conditions for residents and tourists and increased incomes from tourism by protecting water quality and improving the wastewater management infrastructure for expanded tourism development. By all accounts, this is a very high priority throughout the target area. Tourism is vital for the current economy of Istria, the Dalmatian Coast and Adriatic Islands and future development requires action now to maintain the quality of the environment that attracts visitors and to ensure that the expansion of tourism does not despoil that environment. Proper wastewater management is key to current and future growth in all of the coastal areas. Some of the major population centers have wastewater management systems, most of which are being upgraded or need upgrading and expansion. Many of the poorer, less densely populated municipalities, which generally have more fragile environments, have been unable to invest in the infrastructure necessary to manage wastewater properly, however. Moreover, systems need to deal with huge seasonal fluctuations in use, meaning that a small resident population essentially needs to invest in

7 7 infrastructure that serves their own needs as well as those of tourists, who outnumber them many times over. Consequently, smaller and poorer municipalities are caught in a vicious cycle: they cannot afford the immediate investment needed to meet their own needs, let alone systems that are designed to serve short-term summertime populations, and the lack of systems constrains their ability to increase tourist revenues that would help pay for the systems. This Project will enable municipalities to break out of that cycle, providing financial support to build or complete systems quickly, rather than forcing them to rely on piecemeal funding that never allows them to complete the task at hand. The Project will help municipalities find cost-effective solutions to their wastewater management needs either individually or jointly. In all municipalities, the issue has long been a subject of concem and prolonged discussions between citizens, local administrations, MWSCs and HV, some of which have continued for two decades or more. Water utility tariffs are expected to be increased as the result of the Project, but no subprojects will be included without confirming that least-cost solutions are adopted and that a financing mechanism is used to avoid that the anticipated increases impose a significant burden on the population. The subproject specific SA will assess the willingness and ability to pay of the local population. In all instances, one objective of cost recovery will be to ensure that as much of the investment and operations and maintenance costs as feasible and practical are recovered through direct and indirect levies on tourists. The cost of connecting to the new system also needs to be assessed and addressed, if it poses a noticeable burden on people. For people who currently use septic tanks, new water and wastewater tariffs are expected to be lower than their existing costs of maintaining and emptying septic tanks. Subprojects may trigger either OPN 11.03, Cultural Property, or OP 4.12, Involuntary Resettlement. In the first case, the principal issue is chance finds; in the second case, the acquisition of land or rights-of-way. In both cases, Croatia has standard procedures to deal with the issues that are satisfactory to the Bank, detailed in the Project Operational Manual and, in the case of OP 4.12, clarified in the Policy Framework agreed by the Bank (see Annex 13 of the PAD). II.D.lb. Describe any potential cumulative impacts due to application of more than one safeguard policy or due to multiple project component. None expected II.D.lc Describe any potential long term impacts due to anticipated future activities in the project area. In addition to the positive impacts described above, the rehabilitation of the environmental infrastructure in the coastal area will ensure that Project benefits reach beyond the participating municipalities, as improved environmental conditions will enhance prospects for the growth of tourist and fishing activities and improve prospects for the multiplier-effect growth and private sector investment which are expected to accompany the recovery in the tourism sector. As the Country Assitance Strategy for Croatia explicitly recommends, the Project addresses the need for investments in infrastructure to support the development of the tourism sector, which is seen as a key to national growth in the medium term.

8 8 Further, the operation is expected to have important environmental and sector-wide benefits as the Project will assist Government authorities to consolidate their long-term vision for the rehabilitation and efficient provision of water services by sustainable local utilities. The Project will clearly enhance the capacity of local authorities to finance and manage water sector infrastructure during Project implementation and in the future. The Project is expected to have a direct impact on the viability of local utilities in the water sector. Furthermore, the construction/expansion of sewerage networks in participating municipalities, along with the general environmental conditions' improvement in the coastal area, will have significant benefits on the municipalities themselves, since the opportunity to connect new areas to the sewerage network will facilitate municipaluurban expansion, increase the land value of connectable areas and reinforce the potential for economic development of the municipality. II.D.2. In light of 1, describe the proposed treatment of alternatives (if required) II.D.3. Describe arrangement for the borrower to address safeguard issues Operational Manual The Project Operational Manual has provisions to screen for safeguards-ea, Involuntary Resettlement and Cultural Property-and provide detailed guidance for compliance with the safeguards, as appropriate. In particular, to ensure that O.P requirements are met, the Project's Operational Manual contains a separate volume (Volume III) on "Guidelines for Environmental Assessment of subprojects." The Guidelines lay out the procedures of the EA in a format satisfactory to the World Bank. Further, the Project Operational Manual also includes instructions for conducting and making productive use of SAs in each subproject. These SAs provisions are simple and straightforward, offering a standard format to be modified according to local characteristics. These provisions are based on the experience of local consultants who carried SAs in the six municipalities that were identified as likely prospects for inclusion in the first year of the Project: Biograd, Krk, Markaska, Novigrad, Opatija and Zadar. Both portions of the Operational Manual have been reviewed and found acceptable to the Bank. Again, as the provisions in each case are consistent with Croatian laws and practices, they require no additional measures beyond presenting sunmuary reports (EA, Land Acquisition, Cultural Asset Management) to the Bank for review. Compliance will be monitored closely during supervision. Environmental Impact Assessments: During Project preparation, each of the subprojects identified for inclusion in the first year of the Project (Opatija, Krk, Zadar, and Biograd) has obtained a location permit that is required by Law in Croatia before any public work can be executed. As part of this process, as required by the MoE, an EA has been prepared using standards that are acceptable to the Bank. The process to obtain a location permit also includes consultation consistent with the World Bank's requirements. This involved communities and local stakeholders on the selected solution and setting of the proposed infrastructure. Previous (2001) World Bank analysis of Croatia's environmental impact assessment system has shown it to be consistent with EU-EA standards, and highly compatible with World Bank's O.P Therefore, during Project preparation one of the pilot subproject EAs (Zupa Dubrovacka) was translated into English and found satisfactory by the ECA safeguards team. On the basis of this assessment, it was agreed that only the executive summaries of the other first year EAs would be required for review by the World Bank before appraisal. Full EAs for all subprojects in the first year of Project implementation have been

9 9 completed, and these EAs Executive Summaries have been submitted to the Bank together with evidence of their public disclosure. Each EA includes an EMP to address specific local conditions. The Guidelines incorporated in the Operational Manual include details on the preparation of the EMP which describes the mitigation measures for each potential negative environmental impact as well as the responsible party for ensuring the measures are taken. To be eligible for financing under the Project, subprojects in subsequent years will need to have approved location penmits, thus ensuring that an EA is prepared and approved by the MoE. During Phase I of the Project, in conjunction with Component III - Strengthening of the Coastal Waters Monitoring Network - the MoE will prepare a SEA which will analyze the cumulative impacts of the Program on coastal water quality. As part of the monitoring system component, the SEA is included in the triggers for Phase II. Social Assessments SAs, institutionalized in the Project, identify anticipated site-specific social development outcomes and, as appropriate, recommend steps that need to be taken to ensure that they are achieved. Each SA identifies social development issues in each subproject and create a series of benchmarks: current water and wastewater costs (including both sewage tariffs and/or septic tank management costs); current wastewater management practices; willingness and ability to pay for improvements; expectations regarding costs, levels of service and technologies; infonnation levels; and potential "not in my back yard" issues. In addition, each SA will recommend ways to mitigate anticipated problems and to monitor specific issues that need special attention. As indicated above, during preparation, SAs have been carried out in six municipalities that were identified as likely prospects for inclusion in the first year of the Project ( Biograd, Krk, Markaska, Novigrad, Opatija and Zadar). For each subproject, a SA has been and will be included as good practice, based on the experience of the MEIP, which illustrated the problems that can arise in infrastructure development from inadequate consultation and poor public information. These SAs focused on a range of issues common to water and wastewater projects, as well as specific issues suggested by the experience in MEIP. The SAs also highlighted the need for the Project to help HV, MWSCs and local administrations improve their communications and public information skills. In this respect, the Project design will take into account that the subject of communications and public infonmation varies from one site to another, from simple information about plans and implications for cost and repayment to more complicated information about technologies and technological choices, particularly in municipalities where residents and officials are already convinced that they need treatment levels and equipment that may not need and cannot afford. Results of these SAs strongly support the Project concept and indicate that some of the issues that emerged during the implementation of MEIP may not be common in other areas. In each site, wastewater management (water quality) was uniformly recognized as a paramount issue for residents, the reputation of the area and for future development of tourism. Without question, it is a priority concem. In all cases, there is a high level of interest in the Project and high levels of expectations. The results of the SAs have been presented to local stakeholder workshops prior to appraisal, followed by a draft of SAs provisions that were included in the Operational Manual. Involuntary Resettlement (land acquisition)

10 10 The amount of land acquisition that will be required varies considerably, affordability and willingness to pay for improvements is also a variable, and the level and quality of information about altematives and current plans also varies from one site to another, but is generally acceptable. Based on the sample of these six municipalities that were identified as likely prospects for inclusion in the first year of the Project, it is hard to predict the extent to which investments will be subject to the "not in my back yard" response that appeared in MEIP, but this is not expected to represent a problem for implementation if the agreed consultation and dissemination procedures are followed. In this regard, a Resettlement/Land Acquisition Policy Framework was prepared for the Project, based on existing requirements and standard practices in Croatia, which were also demonstrated in the MEIP and reflected in the Policy Framework and field experience of the Rijeka Gateway Project. The Policy Framework has been reviewed and accepted by the Bank, which requires a siniple land acquisition plan for each subproject to be submitted to the Bank for review. Implementation will be monitored carefully during supervision. Proiects in Intemational Waterways According to OP 7.50, notification will be sent to Albania, Serbia and Montenegro, Bosnia and Herzegovina, Slovenia and Italy regarding the Project's content and proposed investments to be financed. II.D.4. 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 in the Project are HV, MWSCs, local administrations, citizens, civil society organizations, such as environmental groups, tourist enterprises, the media and contractors. Investments will be demand driven, thus municipalities and MWSCs will play key roles, in collaboration with HV. Relationships between the three groups are already well established. Although different parties may have differing views on topics such as costs, technologies, and other technical questions, they all have well-defined common interests that the Project will enable them to realize. Citizens have varying degrees of awareness regarding the progress of planning investments and, use both private and public means to raise questions and make their opinions known to decision makers. For the most part, however, there is little systematic public consultation, and public infonmation is erratic, thus there is considerable scope for improving the official/public interface. Public consultation is required as part of the EA process, and public notification is required for construction plans and system alignments, and both requirements will be honored in the preparation and implementation of subprojects. SAs will also offer another opportunity to improve public information and identify fruitful communications strategies for each subproject. To assist municipalities and MWSCs in carrying out these requirements, and improving their standard practices, the SPSC will either include an experienced communications specialist on its staff or retain the services of an experienced public relations firm to help the SPSC and other stakeholders improve their communications and public infonmation skills and practices. E. Safeguards Classification (select in SAP). Category is detennined by the highest impact in any policy. Or on basis of cumulative impacts from multiple safeguards. Whenever an individual safeguard policy is triggered the provisions of that policy apply. ]SI. - Significant, cumulative and/or irreversible impacts; or significant technical and institutional nsks in management of one or more safeguard areas ] S2. - One or more safeguard policies are triggered, but effects are limited in their impact and are technically and institutionally manageable [ S3. -No safeguard issues [X] SF. - Financial intermediary projects, social development funds, community driven development or similar

11 11 projects which require a safeguard framework or programmatic approach to address safeguard issues.

12 12 F. Disclosure Requirements Environmental Assessment/Analysis/Management Plan: Expected Actual Date of receipt by the Bank 11/1/ /8/2003 Date of "in-country" disclosure 3/31/ /28/2003 Date of submission to InfoShop 3/31/ /29/2003 Date of distributing the Exec. Summary of the EA to the Executive Not Available Not Available Directors (For category A projects) Resettlement Action Plan/Framework: Expected Actual Date of receipt by the Bank 11/1/ /15/2003 Date of "in-country" disclosure 3/31/2003 Not Available Date of submission to InfoShop 3/31/2003 Not Available Indigenous Peoples Development Plan/Framework: Expected Actual Date of receipt by the Bank Not Applicable Not Applicable Date of "in-country" disclosure Date of submission to InfoShop Pest Management Plan: Expected Actual Date of receipt by the Bank Not Applicable Not Applicable Date of "in-country" disclosure Date of submission to InfoShop Dam Safety Management Plan: Expected Actual Date of receipt by the Bank Not Applicable Not Applicable Date of "in-country" disclosure Date of submission to InfoShop If in-country disclosure of any of the above documents is not expected, please explain why. Signed and submitted bv Name Date Task Team Leader: Manuel G. Marino 1/9/2001 Project Safeguards Specialists 1: Stan Peabody/Person/World Bank 10/11/02 Project Safeguards Specialists 2: Rita Klees/Person/World Bank 09/24/02 Project Safeguards Specialists 3: Approved by: Name Date Regional Safeguards Coordinator: Jane E. Holt 10/23/02 Sector Manager Sumter Lee Travers 10/22/02