INTEGRATED SAFEGUARDS DATA SHEET RESTRUCTURING STAGE Note: This ISDS will be considered effective only upon approval of the project restructuring Public Disclosure Copy Report No.: ISDSR18601 Date ISDS Prepared/Updated: 04-Aug-2016 Date ISDS Approved/Disclosed: 26-Sep-2016 I. BASIC INFORMATION 1. Basic Project Data Country: Antigua and Barbuda Project ID: P126791 Project Name: Public and Social Sector Transformation Project (PSST) (P126791) Task Team Juan Martin Moreno,Daniela Veronica Felcman Leader(s): Estimated 26-Mar-2013 Estimated 05-Jun-2013 Appraisal Date: Board Date: Managing Unit: GSP04 Lending Specific Investment Loan Instrument: Is this project processed under OP 8.50 (Emergency Recovery) or OP 8.00 (Rapid Response to Crises and No Emergencies)? Financing (in USD Million) Total Project Cost: 10.00 Total Bank Financing: 10.00 Financing Gap: 0.00 Public Disclosure Copy Financing Source Amount Borrower 0.00 International Bank for Reconstruction and Development 10.00 Total 10.00 Environmental B - Partial Assessment Category: Is this a No Repeater project? 2. Current Project Development Objectives The objective of the Project is to assist the Borrower in: (i) strengthening its capacity in managing public policies and the public service; (ii) improving the efficiency of social protection spending through an integrated monitoring and targeting system; and (iii) improving the income and employability of the vulnerable population through temporary employment and training programs. Proposed New PDO (from Restructuring Paper) The objective of the Project is to assist the Borrower in: (i) strengthening its capacity in managing Page 1 of 7 public policies and the public service; (ii) improving the efficiency of social protection spending through an integrated monitoring and targeting system; and (iii) improving the income and employability of the vulnerable population through temporary employment and training programs. Public Disclosure Copy 3. Project Description The proposed Level 1 restructuring would entail revision of the Project Development Objective, and the triggering of new safeguard policies. The restructuring would also include the following changes to the original Project design: (i) closing of all remaining activities under Components 1 and 2; (ii) reallocation of additional funds from Component 1 to Component 5 (Project Management); (iii) cancellation of Component 3; (iv) cancellation of US$3.985 million, thereby reducing the loan amount to US$6.015 million; (v) extension of the Project closing date for one year, to December 31, 2019; and (vi) revision of the Results Framework to reflect changes in components and activities. The restructured Project will be composed of the following: - Component 4: Support ALMPs (maintaining its original allocation of US$4.10 million). The primary objective of this Component is to increase the income and employability of the poor unemployed. Activities will focus on the population between the ages of 17 to 50 years old affected by economic crisis. Two programs are being supported: a Temporary Employment Program (TEP), and a Training Program (TP). The TEP provides income support to the less experienced, low- income, unemployed through temporary employment plus a life-skills training program, while the TP will provide re-training and competence certification to the more experienced among the low-income unemployed population. This approach will allow the Labour Department (LD) to provide employment programs tailored to the employment needs of different groups of the vulnerable populations. The approach will also give the LD flexibility in tailoring employment programs to economic conditions. For example, the TEP can be expanded in times of crisis and contracted during better economic conditions; while in contrast, the TP can be expanded during better economic conditions and scaled down in times of crisis. In terms of process, all TEP beneficiaries will have to comply with workfare activities in the form of refurbishment or small new infrastructure, productive activities, maintenance, and community services. To improve the efficiency in service delivery, the Public Disclosure Copy Project has also financed the creation of the One Stop Job Centre in a central location within the capital St. John's. The Center is responsible for interviewing job seekers; providing job counseling registration to TP and TEP; providing intermediation services; and making referrals to the competency certification system. Additionally, the Project will support the operation of the certification of competencies in the country through the financing of technical assistance for better definition of operational procedures and training of competency assessors. Finally, the Project has supported the implementation of a tracking survey for beneficiaries and the control group to assess the placement rate and the income level resulting from the TEP intervention. - Component 5. Project Management (allocation will increase from US$1.14 to US$1.57 million). This component finances the Project Management Unit (PMU) under the Ministry of Finance. The Project would provide financing to hire a project coordinator, a financial management specialist, and a procurement specialist. This component also finances the required annual financial audits and two process evaluations during project implementation. 4. Project location and salient physical characteristics relevant to the safeguard analysis (if known) Antigua and Barbuda - The Project will be implemented country-wide. 5. Environmental and Social Safeguards Specialists Page 2 of 7 Cristina Elizabeth Coirolo (GSU04) 6. Safeguard Policies Triggered? Explanation (Optional) Public Disclosure Copy Environmental Yes The planned works and services that the Project will Assessment OP/BP 4.01 finance will focus on relatively small sub-projects of community interest (please see below for examples). An Environmental Management Framework (EMF) was prepared by the GOAB. It provides guidance on classifying and evaluating proposed employment activities, using a typology that also will be part of the OM for sub-project screening, design, approval, implementation, and closing. The EMF describes negative environmental impacts that different types of sub-projects could cause and guides on respective management measures to prevent, mitigate or compensate them. The EMF was revised to include the three additional safeguards triggered (below). Natural Habitats OP/BP Yes Some Project activities may be added within designated 4.04 national parks, so the policy is triggered as a precaution. Forests OP/BP 4.36 No The Project will not finance activities that would affect forests or communities that depend on their services Pest Management OP 4.09 Yes Activities are being considered to support potential projects, such as the control of invasive Giant African Land Snails, which would involve pest control products (slug bait), therefore the policy is triggered. Physical Cultural Yes Project activities may be added for assistance with Resources OP/BP 4.11 restoration of historic structures (forts), so the policy is Public Disclosure Copy triggered. Indigenous Peoples OP/ No The Project will not finance activities that would affect BP 4.10 indigenous people groups. Involuntary Resettlement No The Borrower shall not carry out any Project activities OP/BP 4.12 that would result in Resettlement. The Borrower, through MNSL, shall ensure that: (a) any land to be acquired, as part of Project implementation, is acquired on an informed consent for voluntary donation or a willing buyer and willing seller basis, all in a manner acceptable to the Bank, including in accordance with the provisions in theEMF; and (b) prior to such acquisition of land, furnish evidence acceptable to the Bank that the requirements set in the EMF have been satisfied. Safety of Dams OP/BP No The Project will not finance any type of dams or activities 4.37 that would depend on existing dams. Projects on International No The Project will not finance activities that would affect Waterways OP/BP 7.50 international waterways. No There are no disputed areas within the project area Page 3 of 7 Projects in Disputed Areas OP/BP 7.60 II. Key Safeguard Policy Issues and Their Management Public Disclosure Copy 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 Project is classified as Category B given the small-scale, temporary, and reversible impacts that could result from construction sub-projects carried-out primarily with manual labor by up to 15 workers. In order to comply with the OP 4.01, the original EMF was prepared in February 2013 and disclosed in-country in March 2013. The EMF includes a description of the project's eligible activities and includes a negative list on those activities that, because of their nature or potential impacts, will not be supported as reflected in the safeguards table above. In addition, the EMF describes the relevant legal and institutional framework as well as the institutional arrangements for project implementation and its environmental management. The Environment Division (ED) of the Ministry of Agriculture, Lands, Housing and the Environment (MALHE) are responsible for managing environmental issues. The Labour Department Technical Unit (LDTU), responsible for the implementation of the workfare component of the project, coordinates the participation of the ED during the sub-projects' cycle. The project may support an increase in LDTU staff, as required. The EMF was written for the TEP component of the Project, and was developed for simple works that exclude environmentally complex projects such as those that would trigger the natural habitat, physical cultural resources, or pest management policies. However, since the PMU and Labor Department are seeking to expand the base of project beneficiaries and have identified a number of potential sub-projects that would trigger the referenced policies, the EMF has been revised. Therefore, taking advantage that the Project is currently undergoing a restructuring, the policies Public Disclosure Copy have been triggered and the EMF was revised, consulted, and re-disclosed both in-country and through InfoShop. The EMF includes three annexes with specific procedures to mitigate impacts of more complex projects that include the newly triggered safeguards. Activities to be considered under the restructuring could potentially impact physical cultural resources, thus triggering OP4.11, for possible work at three historic sites. The EMP reinforces the provision that all works take place under direct supervision of NPA staff, and that additional training is given to workers to avoid unintentional activities that could inadvertently harm physical cultural resources. This will avoid any ambiguity with the intent of the Policy objective to "assist in the preservation of cultural property and prevent any destruction or damage." The policy has been triggered and an annex included into the revised EMF to provide guidance in the elaboration of EMPs. These activities include labor-intensive works such as weed-cutting to clear brush and help maintain areas which have previously been investigated and/or restored; the capping of brick walls to preserve them until future restoration efforts can begin; and, other clearly defined tasks which are conducted under the direct supervision of the designated authority (NPA) and its site expert. Another safeguard issue for works within the National Park system regards natural habitats. Work on restoration or maintenance of nature trails will require EMPs to ensure that environmental aspects are addressed and that provisions of OP4.04 (Natural Habitats) are followed. Accordingly the policy was triggered and the EMF was revised to include direct supervision of works in these Page 4 of 7 areas by NPA staff. Regarding the Pest Management Policy OP4.09, an example of the a potential sub-project to be Public Disclosure Copy competitively selected under the TEP is the Department of Agriculture's program to monitor and remove the invasive Giant African Snail, which has infested perhaps 70 percent of the island. The snail is highly destructive to flora, is prolific, and carries human disease (rat lungworm nematode). The Government has been addressing the problem since 2008 and in 2014 the Ministry of Agriculture's Chief Plant Protection Officer attended training in Miami-Dade County, USA, where years of experience have kept the pest in check. Most work involves accurate monitoring and observation, as well as community involvement in reporting and collecting the snail, but eradication is also pursued by using bait stations with iron phosphate and metaldehyde. Accordingly, OP4.09 (Pest Management) is triggered. There have been a number of EIAs and studies in Florida that will provide guidelines and the basis for a Pest Management Plan (PMP). Triggering of the pest management policy will also allow for extermination or fumigation of buildings, or use of pest control agents in the Botanical Gardens, if needed. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area: The program is not expected to have any potential large scale issues or irreversible impacts as no major works are contemplated. Typical works anticipated will relate to improvements to existing infrastructure on a small scale. Screening processes to evaluate and management measures to implement sub-projects to assure the proper application of safeguard considerations are detailed in the EMF and the OM. Positive potential impacts can be expected from the presentation and selection of environmental sub-projects aimed at promoting conservation and sustainable use of natural resources and improving environmental conditions of the island. 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. To avoid or minimize potential adverse impacts of sub-projects, the chosen strategy is to restrict the scope of proposals to be presented in competitive selection processes. Besides simplifying Public Disclosure Copy evaluation, this will also imply diminishing potential negative environmental impacts, since complex-to-evaluate sub-projects have been excluded through the negative list. 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. Five basic measures comprise the borrower's strategy to address the safeguards policies: (a) the revision of the current EMF that has been reviewed by the Bank team; (b) the provision of an oversight and consultation role by the Environmental Division of the Government as chief technical body to manage environmental issues; (c) the provision of induction courses for Local Organizations in charge of sub-projects implementation to train them in the process of sub-project proposal presentation to ensure inclusion of adequate environmental and health and safety measures and/or equipment; (d) training for teams of workers in regard to environmental management and health and safety; and (e) a revision of the OM that includes guidelines based on the new EMF and the three additional safeguards triggered under this restructuring, to be followed during the project cycle. The revised EMF was consulted and then disclosed both through InfoShop and in country, on July 26 and July 27, respectively. 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. Page 5 of 7 The main stakeholders are the non-profit Local Organizations such as NGOs and Statutory Bodies responsible for presenting sub-project proposals to develop community-oriented works or services. Beyond the consultation of the revised EMF that took place in July 2016, the induction Public Disclosure Copy courses will be primarily designed for the LOs. This will ensure that local conditions, potential nuisances, and other environmental impacts will be communicated effectively and considered in sub-project design and environmental management plans. The induction course plus the public availability of the EMF are also mechanisms to make the safeguard policies readily available for stakeholders B. Disclosure Requirements Environmental Assessment/Audit/Management Plan/Other Date of receipt by the Bank 19-Jul-2016 Date of submission to InfoShop 04-Aug-2016 For category A projects, date of distributing the Executive Summary of the EA to the Executive Directors "In country" Disclosure Antigua and Barbuda 27-Jul-2016 Comments: Pest Management Plan Was the document disclosed prior to appraisal? NA Date of receipt by the Bank NA Date of submission to InfoShop NA "In country" Disclosure Antigua and Barbuda 27-Jul-2016 Comments: n/a . we are using the EMF disclosure date so that the system allows us to proceed. Please see explanation below. Public Disclosure Copy 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: The specific management plans will be presented jointly with the proposals during the competitive selection process. If approved, the disclosure of the management plans will take place jointly with the approved sub-project. C. Compliance Monitoring Indicators at the Corporate Level OP/BP/GP 4.01 - Environment Assessment Does the project require a stand-alone EA (including EMP) Yes [ ] No [ ] NA [ ] report? OP/BP 4.04 - Natural Habitats Would the project result in any significant conversion or Yes [ ] No [ ] NA [ ] degradation of critical natural habitats? If the project would result in significant conversion or Yes [ ] No [ ] NA [ ] degradation of other (non-critical) natural habitats, does the project include mitigation measures acceptable to the Bank? Page 6 of 7 OP 4.09 - Pest Management Does the EA adequately address the pest management issues? Yes [ ] No [ ] NA [ ] Is a separate PMP required? Yes [ ] No [ ] NA [ ] Public Disclosure Copy If yes, has the PMP been reviewed and approved by a Yes [ ] No [ ] NA [ ] safeguards specialist or PM? Are PMP requirements included in project design?If yes, does the project team include a Pest Management Specialist? OP/BP 4.11 - Physical Cultural Resources Does the EA include adequate measures related to cultural Yes [ ] No [ ] NA [ ] property? Does the credit/loan incorporate mechanisms to mitigate the Yes [ ] No [ ] NA [ ] potential adverse impacts on cultural property? The World Bank Policy on Disclosure of Information Have relevant safeguard policies documents been sent to the Yes [ ] No [ ] NA [ ] World Bank's Infoshop? Have relevant documents been disclosed in-country in a public Yes [ ] No [ ] 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 [ ] No [ ] NA [ ] responsibilities been prepared for the implementation of measures related to safeguard policies? Have costs related to safeguard policy measures been included Yes [ ] No [ ] NA [ ] in the project cost? Does the Monitoring and Evaluation system of the project Yes [ ] No [ ] NA [ ] Public Disclosure Copy include the monitoring of safeguard impacts and measures related to safeguard policies? Have satisfactory implementation arrangements been agreed Yes [ ] No [ ] NA [ ] with the borrower and the same been adequately reflected in the project legal documents? III. APPROVALS Task Team Leader(s): Name: Juan Martin Moreno,Daniela Veronica Felcman Approved By Safeguards Advisor: Name: Date: Practice Manager/ Name: Truman G. Packard (PMGR) Date: 26-Sep-2016 Manager: Page 7 of 7