The World Bank RESTRUCTURING ISDS Third Northern Uganda Social Action Fund (NUSAF 3) (P149965) Integrated Safeguards Data Sheet Restructuring Stage Restructuring Stage | Date ISDS Prepared/Updated: 07-Jun-2017| Report No: ISDSR22382 Regional Vice President: Makhtar Diop Country Director: Diarietou Gaye Senior Global Practice Director: Michal J. Rutkowski Practice Manager/Manager: Dena Ringold Task Team Leader: Michael Mutemi Munavu The World Bank RESTRUCTURING ISDS Third Northern Uganda Social Action Fund (NUSAF 3) (P149965) . I. BASIC INFORMATION 1. BASIC PROJECT DATA Project ID Project Name P149965 Third Northern Uganda Social Action Fund (NUSAF 3) Task Team Leader(s) Country Michael Mutemi Munavu Uganda Approval Date Environmental Category 27-May-2015 Partial Assessment (B) Managing Unit Is this a Repeater project? GSP01 PROJECT FINANCING DATA (IN USD MILLION) Total Project Cost Total Financing 130,000,000.00 130,000,000.00 Financing Gap 0.00 OLD_FIN_DTL Financing Source Amount International Development Association (IDA) 130,000,000.00 Total 130,000,000.00 2. PROJECT INFORMATION Current Project Development Objective The Project Development Objective (PDO) is “to provide effective income support to and build the resilience of poor and vulnerable households in Northern Uganda.� . The World Bank RESTRUCTURING ISDS Third Northern Uganda Social Action Fund (NUSAF 3) (P149965) 3. PROJECT DESCRIPTION The project has four components. The first component contains two sub-components - Labor Intensive Public Works (LIPW) and Disaster Risk Financing (DRF) - that provide temporary/seasonal employment opportunities for poor and vulnerable households and are capable of being scaled up in response to disasters in selected pilot areas. The second component - Livelihood Investment Support (LIS) provides livelihood support to poor and vulnerable households to enable them increase their productive assets and incomes. The third component - Transparency, Accountability and Anti- Corruption (TAAC) - covers activities implemented by the Inspectorate of Government (IG) to improve transparency, accountability, and anti-corruption efforts in northern Uganda. The fourth component - Safety Net Mechanisms and Project Management - provides institutional support to implement the project and help to develop the social protection system that is envisioned in the draft Uganda Social Protection Policy (USPP). Component 1: Labor-intensive Public Works and Disaster Risk Financing LIPW provides beneficiaries from poor and vulnerable households with a seasonal transfer for multiple years in return for their participation in LIPW. Following disasters, the DRF sub-component can be activated in order to scale up the LIPW activities temporarily and rapidly to provide additional support to core LIPW clients and/or to extend coverage to new beneficiaries. The ability to rapidly scale up LIPW is expected to prevent household consumption from dropping after climatic disasters and to protect their livelihoods and assets, leading to a more rapid post-crisis recovery. While the core LIPW sub-component is implemented throughout Northern Uganda, the DRF sub-component is piloted in selected districts to generate adequate evidence on which to base the design of a possible extension of the program to other areas after the midterm review. Component 2: Livelihood Investment Support The Livelihood Investment Support component supports the government’s aim to extend livelihood support to poor and vulnerable households and, by doing so, increases their productive assets and incomes. The LIS component is comprised of an Improved Household Income Support Program (IHISP) and a Sustainable Livelihoods Pilot (SLP). Component 3: Strengthening Transparency, Accountability, and Anti-Corruption (TAAC) Under NUSAF 3, the TAAC component is tailored in such a way as to contribute to the government’s commitment to increasing transparency and accountability in public service delivery as enshrined in Vision 2040, the NDP, and the Accountability Sector Strategic Investment Plan (ASSIP). The strengthened TAAC enhances the effectiveness of transparency, accountability, and anti-corruption processes in project areas. Component 4: Safety Net Mechanisms and Project Management. The Safety Net Mechanism aims to lay the foundation for a social safety net system as envisioned in the draft Uganda Social Protection Policy (USPP). The component supports the MGLSD in establishing and strengthening systems to promote the harmonization of the direct income support elements of the social protection sector. The Project Management supports the operational expenditures related to the management and the monitoring and evaluation of the project. Its support will strengthen the planning and coordination of activities supported by the project, as well as the monitoring of their implementation. . 4. PROJECT LOCATION AND SALIENT PHYSICAL CHARACTERISTICS RELEVANT TO THE SAFEGUARD ANALYSIS (IF The World Bank RESTRUCTURING ISDS Third Northern Uganda Social Action Fund (NUSAF 3) (P149965) KNOWN) The project will provide support in a limited number of districts, prioritizing the 56 districts in the north and east of the country that participated in the NUSAF 2. It will also coordinate with the WFP-implemented Cash/Food for Assets program to minimize overlap in these areas. The project will support interventions designed to improve livelihoods and access to basic socio-economic services in selected districts. The salient physical characteristics relevant to safeguard analysis relate to project Component 1: Labor-Intensive Public Works and Disaster Risk Financing and Component 2: Livelihood Investment Support. Component 1 involves public works which will focus on a variety of asset creation activities, including rural access roads, tree nurseries, afforestation, construction of different soil and water conservation measures, and flood control structures, rainwater harvesting, rehabilitation and construction of market shelters, among others. Component 2 will support livelihood investments which may involve Value-addition to existing family-based small income generating activities. The overall environmental and social impacts of the project is expected to be positive through alleviating pressures on the poor that lead to unsustainable exploitation of natural resources and environmental degradation. The community sub-projects may involve limited land acquisition and displacement of land-uses and/or livelihoods. Therefore, by their nature, project components 1 and 2 may have limited and localized negative environmental and social impacts. For this reason, the project is rated as EA category B. The project ties in the twin goals of the World Bank group of alleviating poverty and promoting shared prosperity. The potential environmental and social impacts can be adequately managed by integrating environmental and social due diligence into the sub-project cycle. Since the multiple CDD sub- projects and locations are not yet known at this time, Environmental and Social Management Framework (ESMF) and Resettlement Policy Framework (RPF) have been prepared and disclosed both in-country and at infoshop before project appraisal. In addition, through restructuring process, a VMPP was prepared through a consultative process to offer special attention to the IK. The Ik community is found in Kaabong District, in the North Eastern part of Uganda, within the Karamoja sub-region. The instrument was disclosed in-country and the Bank's infoshop for a wider access. 5. ENVIRONMENTAL AND SOCIAL SAFEGUARDS SPECIALISTS ON THE TEAM Constance Nekessa-Ouma, Social Safeguards Specialist Sammy Ratemo Kinara, Environmental Safeguards Specialist SAFEGUARD_TABLE 6. SAFEGUARD POLICIES TRIGGERED Safeguard Policies Triggered Explanation Because of the public works and livelihoods support projects there are likely negative environmental and social impacts to be generated, though localized and readily manageable. Since the specific Environmental Assessment (OP) (BP 4.01) Yes multiple sub-projects and their locations are not yet known, an Environmental and Social Management Framework has been prepared to guide implementation of the environmental and The World Bank RESTRUCTURING ISDS Third Northern Uganda Social Action Fund (NUSAF 3) (P149965) social aspects. The ESMF has been prepared in a consultative manner, and disclosed both in-country and at info-shop before project appraisal. Specific safeguard instruments (ESIA, ESMPs) shall be prepared during project implementation following guidance in the ESMF. The project shall not support any activities that Natural Habitats (OP) (BP 4.04) No affect natural habitats. The policy is not triggered because NUSAF-3 supported activities will not have any direct impacts on the health and quality of forests, or on Forests (OP) (BP 4.36) No the health and safety of people who depend on forests. There is no intention to change the management, protection, or utilization of forests. Under project Component 2 Livelihoods Support, the project may support CDDs that involve small Pest Management (OP 4.09) Yes scale use of pesticides that may be applied to veterinary care of animals. A Pest Management Plan has been included in the ESMF. The civil works involved in Component 1 of Public Works may impact on known and/or unknown PCRs Physical Cultural Resources (OP) (BP 4.11) Yes and therefore a Chance Finds Procedure has been included in the ESMF. NUSAF 3 was designed as a Community Demand Driven (CDD project. In light of the project design, that encompasses enhanced participatory and broad consultative criteria, the assessment at preparation did not find it necessary to trigger OP 4.10. However, this was reassessed in order to ensure that the Ik; which is a minority community found in Kaabong District in Karamojong region; is Indigenous Peoples (OP) (BP 4.10) Yes specifically benefiting from the project, thus triggering of OP 4.10. The project has undergone restructuring to trigger OP 4.10. The client has prepared a Vulnerable and Marginalized Peoples Action Plan (VMPP) in a participatory and consultative manner. The VMPP was cleared by the Bank on August 8, 2017, after which it was disclosed in-country and on the World Bank’s web sit on October 3, 2017.. Because of the likely small scale land acquisition and impact on the livelihood of communities, this Policy is triggered. Since the multiple CDDs are not Involuntary Resettlement (OP) (BP 4.12) Yes yet known including their location, a Resettlement Policy Framework has been prepared, consulted upon and disclosed both in-country and at infoshop before project appraisal. The World Bank RESTRUCTURING ISDS Third Northern Uganda Social Action Fund (NUSAF 3) (P149965) The project involves the construction of flood control structures and ponds for rain water harvesting, but these do not pose dam safety risks. However, the construction of these works will be Safety of Dams (OP) (BP 4.37) No guided by the Small Dam Guidelines prepared for Uganda and the FAO Manual on small Earth Dams. The project is not supporting the construction of dams. Projects on International Waterways (OP) The project will not be implemented in No (BP 7.50) International Waterways. N/A because the project will not support any Projects in Disputed Areas (OP) (BP 7.60) No activity in disputed areas. KEY_POLICY_TABLE II. KEY SAFEGUARD POLICY ISSUES AND THEIR MANAGEMENT A. SUMMARY OF KEY SAFEGUARD ISSUES 1. Describe any safeguard issues and impacts associated with the Restructured project. Identify and describe any potential large scale, significant and/or irreversible impacts. The salient physical characteristics relevant to safeguard analysis relate to project Component 1: Labor-Intensive Public Works and Component 2: Livelihood Investment Support. Components 1 & 2 may generate among others the following environmental and social impacts: Health and safety issues: The civil works and use of pesticides will pose health and safety issues. These shall be addressed first and foremost by providing and ensuring use of appropriate PPE. In addition, workers and farmers shall be sensitized and/or trained on the importance and use of PPE in civil works and use of pesticides; Vegetation clearance and soil erosion: The likely environmental and social impacts of community access roads rehabilitation are expected to be minor given the low mechanized road works that will be involved. Where loses of vegetation are inevitable, compensation measures shall be instituted as per approved Government rates and as outlined in the RPF for NUSAF 3; Impacts on PCRs – There may be graves or other physical cultural resources along proposed community access routes. The subsequent environmental and social assessments should take into account specific measures to address mitigations for such resources during project implementation. As for this ESMF, it is proposed that, the design stages should propose alignments that avoid graveyards. In addition, measures outlined in the Chance Finds Procedures should be operationalized as well; Waste Management – One critical issue observed during NUSAF 2 was waste management especially hazardous waste. The NUSAF 3 Waste Management Plan (WMP) has been prepared to address waste management issues associated with the NUSAF3 project in line with legal and regulatory requirements as detailed in Annex 5 of the ESMF. Component 2 may involve use of pesticides and other veterinary chemicals or result in their increased usage through Livelihoods Investments support and triggers OP 4.09 on pest management. The subprojects are expected to have only minor use for nationally approved pesticides; otherwise there will not be significant pesticide use in subprojects. Where pesticide use will be required, District and sub-county extension staff (agricultural and veterinary officers/assistants) will train farmers on appropriate use, storage and disposal of pesticides. The project will also be implemented in Karamoja region, in Kabong District hosting a recognized minority group of people called the IK, who despite the community demand driven approach used in the project implementation was The World Bank RESTRUCTURING ISDS Third Northern Uganda Social Action Fund (NUSAF 3) (P149965) noted to require special attention. An VMPP was prepared by the client to address the special needs of the IK. A budget to support the special activities was planned for the potential activities. The assessment has taken into account the potential social risks that might undermine benefit and participation of the vulnerable members of the community such as women, children, elderly, disabled and regions which are historically marginalized (Karamoja). specific consideration to ensure that all these groups benefit from and participate in the project though effective targeting and meaningful consultations are in place. There are no potential large scale, significant and/or irreversible impacts associated with the project. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area. None 3. Describe any potential alternatives (if relevant) considered to help avoid or minimize adverse impacts. None 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. Since the exact location of the CDDs is not known at this stage, a framework approach was adopted. The borrower has prepared ESMF and RPF which were both cleared by IDA and disclosed both in-country and at infoshop before project appraisal. The ESMF gives a step by step guidance on how to screen, identify, assess, mitigate and manage any environmental and social impacts that the project may pose, including monitoring and reporting. Where necessary and based on the screening outcome as guided in the ESMF, site specific ESIAs/ESMPs shall be prepared during implementation. Similarly the RPF gives a step by step guidance of how to screen, identify, assess, mitigate and manage social impacts including involuntary resettlement issues. It gives guidance on how consultations and compensation are undertaken, including preparation of RAPs where deemed necessary. The client has committed to undertake any arising compensation in line with OP 4.12. Both the ESMF and RPF provide guidance on establishment and operation of a Grievance Redress Mechanism to address any complaints that the project may generate. The ESMF has also provided guidance/Pest Management Plan (PMP) on the use and management of pesticides under sub- component 2. It gives basic guidance on the procurement, transportation, storage, handling and application of pesticides, including disposal of the empty pesticides containers. This guidance shall later be part of the Project Operations Manual. The purpose of the PMP is to describe a Plan by which the project can promote and support safe, effective, and environmentally sound pest management. The institutional arrangement which has been used to implement the NUSAF 2 project will be used to implement NUSAF3 project. The Office of the Prime Minster (OPM) will be the implementing agency of the project and will work with a wide range of institutions at central, district and sub-county levels to deliver the project. The OPM will continue to be supported by a Technical Support Team headed by a Project Coordinator and staffed by relevant technical experts. The exact composition and number of staff will be reviewed following further elaboration of the design but it is expected that the team will have a cost effective structure and more practical presence. OPM will consolidate and review monthly reports submitted by the different agencies. At the district level, the District Environment Officer (DEO) and Community Development Officer (CDO) will monitor environmental and social issues respectively. The World Bank RESTRUCTURING ISDS Third Northern Uganda Social Action Fund (NUSAF 3) (P149965) An VMPP was prepared by the client to address the special needs of the IK. A budget to support the special activities was planned for the potential activities. The instrument includes guidance on community targeting for the vulnerable communities and persons, meaningful consultation, and an enhanced community based grievance handling approach to be employed during implementation. The instrument was cleared by the bank and disclosed both in-country and infoshop. NUSAF-TST has a qualified Environment and Social Specialist and Technical Support Team, who will be equally responsible for implementing the VMPP as a stand alone and an integrated part of the project in close collaboration with relevant local government staff and communities. 5. Identify the key stakeholders and describe the mechanism for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. The key stakeholders consulted include the Inspectorate of Government Office, Ministry of Water and Environment, Ministry of Education and Sports, Ministry of Health, Ministry pf Gender Labour and Social Development, Ministry for Karamoja Affairs, NUSAF District Desk Officers, District Environment Officers, District Health Officers, NUSAF2 beneficiary communities and groups including the IK people, general communities, etc. More stakeholder and community consultations shall be undertaken as part of project implementation, as dictated by the nature of the project. The consultations were undertaken through focused group discussions, questionnaire administration, community meetings organized through the local leaders. The national level meetings were undertaken through individual appointments and face to face talks guided by interview schedule. The ESMF and RPF have been disclosed both in-country and at infoshop. In-country disclosure was undertaken through a disclosure notice in the daily newspapers, through the websites of OPM-NUSAF, and MGLSD. Consultation process will go on during the construction and operation phases of the project. To this effect, OPM will be required to maintain long term and mutually beneficial open dialogue with local authorities and the public through its Social and Environmental Safeguards Specialists and Officers during implementation. The majority of the target beneficiaries include Internally Displaced Persons (IDP) returnees, widows, Orphans, People living with HIV/Aids, Ex- combatants, former abductees, female headed households, child mothers, unskilled and unemployed youth, disarmed Karamojong, youth, Elderly, Child head families, Persons with disability and Landmine victims. Interest in the NUSAF3 will therefore vary among different vulnerable groups (and individuals) in the community, and they may be affected differently. It will be important to keep this in mind during the consultation process, and in some cases it may be more appropriate to consider the needs and priorities of sub-communities rather than those of a whole village. The required consultations during implementation are well elaborated in the ESMF and shall be followed. The VMPP benefited from double consultation process during the project consultation and during the specific instrument preparations which has also had extensive follow-ups and community disclosures. The process was participatory involving Local Government teams, Community based organizations and IK communities. DISCLOSURE_TABLE B. DISCLOSURE REQUIREMENTS ENV_TABLE The World Bank RESTRUCTURING ISDS Third Northern Uganda Social Action Fund (NUSAF 3) (P149965) Environmental Assessment/Audit/Management Plan/Other Date of receipt by the Bank Date of submission for disclosure For Category ‘A’ projects, date of distributing the Executive Summary of the EA to the Executive Directors “In country� Disclosure Country Date of Disclosure Uganda 14-Apr-2015 Comments RESETTLE_TABLE Resettlement Action Plan/Framework Policy Process Date of receipt by the Bank Date of submission for disclosure “In country� Disclosure Country Date of Disclosure Uganda 14-Apr-2015 Comments INDIG ENOUS_TAB LE Indigenous Peoples Development Plan/Framework Date of receipt by the Bank Date of submission for disclosure 22-Feb-2017 03-Oct-2017 “In country� Disclosure Country Date of Disclosure Uganda 03-Oct-2017 The World Bank RESTRUCTURING ISDS Third Northern Uganda Social Action Fund (NUSAF 3) (P149965) Comments in New Vision Newspaper PEST_TABLE Pest Management Plan Was the document disclosed prior to appraisal? Date of receipt by the Bank Date of submission for disclosure “In country� Disclosure Country Date of Disclosure Uganda 14-Apr-2015 Comments COMPLIANCE_TABLE C. COMPLIANCE MONITORING INDICATORS AT THE CORPORATE LEVEL EA_TABLE OP/BP/GP 4.01 - Environment Assessment Does the project require a stand-alone EA (including EMP) report? No PM_TABLE OP 4.09 - Pest Management Does the EA adequately address the pest management issues? Yes Is a separate PMP required? No If yes, has the PMP been reviewed and approved by a safeguards specialist or PM? Are PMP requirements included in project design? If yes, does the project NA team include a Pest Management Specialist? PCR_TABLE OP/BP 4.11 - Physical Cultural Resources Does the EA include adequate measures related to cultural property? Yes The World Bank RESTRUCTURING ISDS Third Northern Uganda Social Action Fund (NUSAF 3) (P149965) Does the credit/loan incorporate mechanisms to mitigate the potential adverse Yes impacts on cultural property? IP_TABLE OP/BP 4.10 - Indigenous Peoples Has a separate Indigenous Peoples Plan/Planning Framework (as appropriate) Yes been prepared in consultation with affected Indigenous Peoples? If yes, then did the Regional unit responsible for safeguards or Practice Manager Yes review the plan? If the whole project is designed to benefit IP, has the design been reviewed and NA approved by the Regional Social Development Unit or Practice Manager? IR_TABLE OP/BP 4.12 - Involuntary Resettlement Has a resettlement plan/abbreviated plan/policy framework/process framework Yes (as appropriate) been prepared? If yes, then did the Regional unit responsible for safeguards or Practice Manager Yes review the plan? Is physical displacement/relocation expected? Is economic displacement expected? (loss of assets or access to assets that leads to loss of income sources or other means of livelihoods) PDI_TABLE The World Bank Policy on Disclosure of Information Have relevant safeguard policies documents been sent to the World Bank for Yes disclosure? Have relevant documents been disclosed in-country in a public place in a form and language that are understandable and accessible to project-affected groups Yes and local NGOs? ALL_TABLE All Safeguard Policies Have satisfactory calendar, budget and clear institutional responsibilities been Yes prepared for the implementation of measures related to safeguard policies? Have costs related to safeguard policy measures been included in the project Yes cost? The World Bank RESTRUCTURING ISDS Third Northern Uganda Social Action Fund (NUSAF 3) (P149965) Does the Monitoring and Evaluation system of the project include the monitoring Yes of safeguard impacts and measures related to safeguard policies? Have satisfactory implementation arrangements been agreed with the borrower Yes and the same been adequately reflected in the project legal documents? III. APPROVALS Task Team Leader(s) Michael Mutemi Munavu Approved By Safeguards Advisor Practice Manager/Manager .