INTEGRATED SAFEGUARDS DATA SHEET APPRAISAL STAGE . Report No.:ISDSA20473 Date ISDSPrepared/Updated: 11-Jan-2018 Date ISDS Approved/Disclosed 11-Jan-2018 I. BASIC INFORMATION 1. Basic Project Data Country: Vietnam Project ID: P152232 Project Name: Vietnam HCFC Phaseout Project Stage II (P152232) Task Team Leader(s): Qing Wang,Katelijn Van den Berg Estimated Appraisal 27-Dec-2017 Estimated Board 15-Mar-2018 Date: Date: Managing Unit: GEN2B Financing Investment Project Instrument: Financing Is this project processed under OP 8.50 (Emergency Recovery) or OP No 8.00(Rapid Response to Crises and Emergencies)? Financing (In USD Million) Total Project Cost: 14.64 Total Bank Financing: 0.00 Financing Gap: 0.00 Financing Source Amount Borrower 0.00 Montreal Protocol Investment Fund 14.64 Financing Gap 0.00 Total 14.64 Environmental Category: B - Partial Assessment Is this a Repeater project? No 2. Project Development Objective(s) The project development objective is to reduce HCFC consumption in order to assist Vietnam meet its HCFC phase-out obligations under the Montreal Protocol, and to reduce greenhouse gas emissions arising from the replacement of these HCFCs. 3. Project Description The Stage II project is a continuation of the ongoing Stage I project and the project duration is expected to be from 2017 to 2022. The project consists of three proposed components described below. Component 1: HCFC Consumption Reduction (US$ 13.56 million) Page 1 of 11 AC manufacturing and servicing sector. The project will finance incremental capital costs (ICC) needed for converting to non-HCFC based AC production including procurement of new production equipment, performance testing of new AC models, and technician training for installation and servicing, and incremental operating cost (IOC) based on MLF financing guidelines at four enterprises (consuming a total 175 MT of HCFC-22 in 2014). After conversion at the four enterprises, no HCFC-22 will be used for AC production in the entire sector, i.e. 251 MT of HCFC-22 will be completely phased out. The approved funding is US$2.18 million. The lower GWP alternatives to HCFC-22 in the AC sector are HFC-32 with a GWP 675 or R-290 with a GWP of 5, however both are flammable which will require special safety precautions and investments. Due to its classification as an A2L refrigerant, mildly flammable refrigerant, HFC-32 requires that certain measures be put into place before its wider use in Vietnam, including in manufacturing. TA will be needed specifically for effective adoption of this technology. Given its recent experience in this area including related to HFC-32 regulation, Japan has been approved under the MLF to provide TA as the Cooperating Agency while drawing practical expertise from Japanese AC manufacturers through JRAIA. TA activities are proposed at a total cost of $233,630: development of A2L policy measures, TA to the AC manufacturers, and TA for good practice in installation and operation. An additional 66.3 MT in HCFC-22 phase-out is expected from the AC servicing and Japan TA activities. Refrigeration manufacturing sector. The project will finance conversion of priority industrial refrigeration systems where cost-effective and low GWP alternatives (e.g. ammonia, hydrocarbons, HFC-32, etc.) are available through ICC (for system, component and process redesign, new equipment, performance verification, and safety training) and IOC at about 34 enterprises which are eligible for MLF funding. Approved funding is US$3.64 million. A reduction of 303 MT will be achieved by project closing. The implementation of HCFC phase-out in the refrigeration sector will be phased, whereby 6-10 demonstration subprojects for applications including ice making units, stand-alone refrigeration units, cold storage rooms, and condensing units will be started at the beginning of the Stage II project. As soon as a body of experience has been accumulated, the knowledge will be used by experts to inform remaining companies. Refrigeration servicing sector. The project will finance the following activities in the refrigeration servicing sector: training and certification in good servicing and maintenance practices, provision of servicing tools to selected vocational training centers to enable training in the handling of alternative flammable refrigerants and to selected servicing shops to inform the sector on alternatives and prepare for Stage III, TA demonstration for 10 selected industrial refrigeration end users on HCFC leakage management. The approved funding is US$1.37 million for an HCFC-22 phase-out impact of 285.3 MT. Foam sector. The project will finance ICC needed for foam production conversion to hydrocarbon, methyl formate or HFO (hydrofluoroolefin) alternatives at about 44 enterprises. After completion of conversion at these enterprises, it will be prohibited to use HCFC-141b contained in pre-blended polyol for foam production in the whole sector. About 2035 MT of HCFC-141b will be completely phased out. In order to allow SMEs (consuming less than 20MT of HCFC-141b) to convert to non-HCFC production in a cost-effective way, the project will also finance upgrading of two to four system houses to be competitively selected among existing foam producers or chemical suppliers that have established the basic system house infrastructure. These system houses would supply non-HCFC pre-blended polyol to SMEs. In addition, the project will finance conversion at an enterprise which used HCFC-22 of 100 MT in 2014 for XPS foam production. The approved funding for HCFC-141b phase-out and HCFC-22 phase-out in the foam sector is US$5.52 million and US$613,568 respectively. Implementation in the foam sector will also be phased due to the limited funding approved in contrast to the large amount of HCFCs used. The largest consumer of pre-blended HCFC-141b polyol systems in Vietnam is the insulated roofing panel manufacturing industry. This subsector is made up of primarily SMEs in real terms. Page 2 of 11 Therefore, four demonstration projects including establishment of system houses for the roofing subsector will be initiated first at the beginning of the Stage II project. Component 2: Technical Assistance and Policy Actions (US$ 406,801) This component aims to support sector-wide technology and knowledge transfer, TA and exchange of best practices, as well as to create a policy and market environment that will enable and sustain sector transformation. TA activities focusing on the AC, refrigeration and foam manufacturing sectors will include training workshops on subproject preparation, approval and implementation procedures and requirements, international and national technical consultant services for subproject appraisal and technical support for the PMU and enterprises, development of technical standards of alternatives, training for government officials, training on the safe use of alternatives, study tours on HCFC alternatives, a joint study on integrating HCFC phase-out and EE improvement in the industrial refrigeration manufacturing and food process sectors, and others as needed. On policies, this component will cover the annual HCFC import quota issuance and the development and issuance of sector-specific policy and regulations by project completion, including a ban on local production and import of HCFC-22 based ACs, and a ban on import and use of pre-blended HCFC-141b polyol in foam production. Component 3: Project Management (Estimated US$ 678,001) The PMU currently implementing the Stage I HCFC Phase-out Project will most likely continue with financial, procurement, and safeguard management as well as monitoring and reporting responsibility. This component will finance the PMU staff including one project coordinator, two project officers, one procurement officer, one accountant and one administrative officer, project launch and completion workshops, financial audits, annual HCFC consumption verification, public awareness activities, and incremental operating cost (of the PMU). 4. Project location and Salient physical characteristics relevant to the safeguard analysis (if known) The project will involve HCFC conversion at about 80 enterprises in air-conditioning, refrigeration, and foam manufacturing sectors around the country. A long list of potential participating beneficiary enterprises in these sectors has been identified during project preparation. The final beneficiary enterprises will only be confirmed during project implementation when subproject proposals are prepared by enterprises and appraised by the PMU. Ammonia, HFC-32 and hydrocarbons, which are flammable materials, are the main alternatives to be adopted by the project. This could lead to safety issues for which proper safety equipment, measures and training should be put into place. 5. Environmental and Social Safeguards Specialists on the Team Ha Thi Van Nguyen, Social Safeguards Specialist Quang Nhat Nguyen, Social Safeguards Specialist Son Van Nguyen, Environmental Safeguards Specialist Van Trung Nguyen, Social Safeguards Specialist 6. Safeguard Policies That Might Apply Safeguard Policies Triggered? Explanation (Optional) Environmental Assessment OP/BP 4.01 Yes The project will have a positive impact on the global environment by reducing the use of HCFCs, Page 3 of 11 which are ozone-depleting substances and greenhouse gases with a GWP ranging from several hundred to several thousand times that of CO2. The project will contribute to about 2.9 million CO2 tons equivalent emission reduction per year after completion. It will support Vietnam to meet the 2020 HCFC phase-out obligation (35% reduction of the baseline), eliminating the consumption of HCFCs of 1,006 MT. The project will include a series of investment activities and replace the HCFC use with the other alternative gases or refrigerants (hydrocarbons, HC- 290, HFC-32, ammonia) in the existing AC, refrigeration and foam manufacturers. No closure of these enterprises is expected due to the project. Most of these enterprises are located in industrial area, but some SMEs are located in residential area. While HCFCs have an impact on global climate change, they have no adverse local impact as these chemicals are stable and not considered toxic or dangerous for the environment. The alternative gases or refrigerants have zero ODP and lower GWP but high flammability, and therefore, have high risk of fire and explosion. Few may result in environmental impacts if it is mishandled. Ammonia (NH3) is also a toxic gas. The manufacturing process also involves potential occupational and health safety issues. Therefore, OP 4.01 is considered triggered. EMPs, one for each of the three sectors (foam, AC and refrigeration) have been prepared and will be followed by the participating enterprises during subproject implementation. Natural Habitats OP/BP 4.04 No The project will not affect any protected areas, known natural habitats, or established or proposed critical natural habitats as all the project activities will take place within the existing plant boundaries either located in industrial zones or residential areas, thus there is no impacts on natural habitat. Forests OP/BP 4.36 No There is no proposed investment involving forest harvesting or forest management. Pest Management OP 4.09 No The project does not involve the procurement or use of any pesticides or herbicides or result in an increase in pesticides usage. Physical Cultural Resources OP/BP 4.11 No Given the project location and activities it will not adversely affect sites with archeological, paleontological, historical, religious, or unique Page 4 of 11 natural values. Indigenous Peoples OP/BP 4.10 No All sub-projects will be implemented within existing project enterprises or in industrial area, so there is no IP group to be affected. Therefore, the project will not trigger this policy. Involuntary Resettlement OP/BP 4.12 Yes All sub-projects will be likely implemented within existing enterprises, so land related impact are not expected. However, some SMEs will possibly be relocated to industrial areas as per the request of local governments, the policy is therefore triggered. A Resettlement Policy Framework has been prepared to guide relocation and potential land issues if any during preparation of the subproject proposals (during the overall project implementation stage. Due diligence review for five first enterprises confirmed that they had fully complied with government regulation, and there were no legacy issues pending to be solved. During implementation, the borrower will ensure that following the RPF proper screening be carried out and reported for the Bank’s due diligence review. Safety of Dams OP/BP 4.37 No There is no construction or rehabilitation of dams or dykes. Projects on International Waterways OP/BP No The project does not have any impact on any 7.50 international waterway. Projects in Disputed Areas OP/BP 7.60 No No The project is not located in any disputed areas. . II. Key Safeguard Policy Issues and Their Management A. Summary of Key Safeguard Issues 1. Describe any safeguard issues and impacts associated with the proposed project. Identify and describe any potential large scale, significant and/or irreversible impacts: The project is classified as a Category B project. No large-scale, significant and/or irreversible impacts are expected. The project, under Component 1, will finance phase-out of 1,006 MT HCFC-22 from four AC manufacturer, about 34 refrigeration manufacturers, one XPS foam manufacturer, and the refrigeration and AC servicing sectors. The project will also finance complete phase-out of HCFC-141b (about 2,035 MT) in pre-blended polyol in about 44 foam manufacturers. The project activities will likely occur in the existing facilities, even though flammable substances such as ammonia, R-32 and hydrocarbons (R-290 or cyclopentane) will be used, which may create safety and occupational health issues. These impacts, with more details provided below, are site specific and can be mitigated with appropriate mitigation measures. Page 5 of 11 Air-conditioning production sector: In the AC sector, the HCFC-22 (R-22) is converted to the proposed alternative gases: HFC-32 with GWP of 675 (about 1/3 that of HCFC-22) or HC-290 with a GWP of 5, both have zero ozone depletion potential (ODP). However, they are flammable as ISO 817-2014 classified as A2L (lower toxicity, lower flammability) and A3 (lower toxicity, higher flammability) chemicals, respectively. Therefore, these two alternatives have safety risks and fire hazards must be properly addressed. Direct contact of HFC-32 can also be harmful to skin, and its inhalation or eye contact could cause significant effects or critical hazards as well. Other chemical involved in air-conditioning production is the synthetic Polyol ester (POE) oil. POE oil is completely wax-free and is the best choice of lubricants due to their better thermal stability, more miscible and highly biodegradable. When POE oils are exposed to moisture and heat, they may react, forming acid that is harmful to the system and difficult to be recovered. The recovery technique should be selected to avoid discharge which could cause water or soil pollution. The potential refrigerating effect of HFC-32 is 1.5 times better than that of HCFC-22. More specifically, pressure losses are lower with HFC-32 than HCFC-22 for the same capacity and the liquid density of HFC-32 is also 10% lower. Thus the piping diameter can be smaller. As a result, the charging volume can be 30% less than with HCFC-22. The cooling seasonal performance factor (CSPF) of HFC-32 is higher than conventional refrigerants. Its peak power consumption is also lower, helping to alleviate power shortages in large cities during periods of high demand. Refrigerator production sector: In the refrigeration sector, ammonia, HC-290 and HFC-32, are proposed alternatives to HCFC-22. Ammonia, which has zero GWP, is widely used for large distributed systems and large chillers. This refrigerant is an important option for many industrial refrigeration applications. However, ammonia is toxic and flammable (classified as B2L-lower flammability, higher toxicity) – appropriate safety precautions are required. NH3 may explode if heated; toxic if inhaled, causes severe skin burns and eye damage, very toxic to aquatic life; corrosive to the respiratory tract. There are also potential environmental and occupational health and safety (OHS) risks associated with inappropriate handling of these chemicals/gases, which could be caused by chemical spills or fire and explosion. Therefore, good operational procedures and mitigation measures should be effectively taken at all enterprises supported by the project. Extruded polystyrene (XPS) foam: The XPS foam production will use CO2 with Alcohol/DME/ u-HFC technology. The chosen technology is a low-GWP based system, which is a definitive alternative under the Montreal Protocol (MP) and additionally has a positive impact on climate and are not adverse to the environment, in compliance with MP Decision XIX/6. Polyurethane (PU) Foam production sector: Hydrocarbon (cyclopentane) and CO2 have been selected as blowing agents to replace HCFC-141b. Hydrocarbon has a GWP of less than 25. Cyclopentane is classified as a Volatile Organic Compound (VOC), but its use results in very low levels of emissions of about 2-3% of the blowing agent, which results in minuscule emissions, compared for example, to emissions from two-stroke motorcycle traffic in urban areas. Therefore, there is no significant environmental impact from the cyclo-pentane itself. However, due to its flammability, safety requirements associated with hydrocarbons are important and should be in place. Page 6 of 11 The other chemicals involved in foam production are Methylene Diphenyl Isocyanate (MDI), polyol, amine catalysts and fire retardants. The probability that a spill of polymeric MDI - a liquid at room temperature – the risk of contaminating the soil and water is very low, because the floor of the foam production areas consists of cement coated with an anti-leakage, low permeability/chemical layer such as epoxy. In the case that MDI leaks into the soil, it will react with moisture, and the reaction would result in CO2 and insoluble polyurea compounds, which are not biodegradable but chemically inert. MDI may cause health impacts such as eye, respiratory system and skin irritation. Exposure via skin contact and inhalation can result in respiratory sensitization. Fire retardant and amine catalysts (use very little amount) are mixed/pre-formulated in the polyol at the system houses (pre-blended polyol suppliers), from which the foam enterprises purchase pre-blended polyol and MDI, so the foam enterprises will not handle these toxic chemicals directly. Fire retardant and amine catalysts will remain in the final foam products and are not likely to be emitted to the environment during the foam production or later. Therefore, there are no anticipated legacy environmental contamination issues that are associated with foam production. Methylene chloride is the cleaning agent now used in the foam production process. It can affect the body if it is inhaled or if the liquid comes in contact with eyes or skin or is swallowed. Methylene chloride can be a hazardous waste but only when present in large quantities and high concentrations, as defined in Vietnamese regulations. However, only small quantities are used in foam production and the mixing heads for the new cyclopentane based foaming units to be purchased under the project will facilitate the phase-out of the use of methylene chloride as a cleaning agent. In the second phase project, the system houses will be invested to provide the pre-blended polyol for the other small and medium foam production enterprises to help them get rid of HCFC-141b with less investment as well as minimize the impacts and chemical risks for those SMEs. Lastly, since some enterprises might need to move in industrial zones requiring small scale construction activities. This would cause some construction related impacts which are expected to be small and can be addressed through application of the Environmental Codes of Practices (ECOPs) which are included in the EMPs. The impacts of non-hazardous solid waste generated during AC, refrigeration manufacturing and foam production process are also expected to be small and will be addressed in the subproject EMPs. OP4.10 Indigenous People: is not triggered, as the project scoping confirmed that there are no ethnic minority peoples in project areas, as HCFC conversion will be carried out in existing enterprise location or industry zones (IZ) to which some enterprises may be relocated. OP4.12. Involuntary Resettlement is considered triggered. Although the project investment will not result in any new or additional involuntary resettlement, some enterprises have or will have to be relocated to IZs per the Government’s land planning request when preparing or implementing their subprojects (which might result in involuntary resettlement). There is no potential large scale, significant and/or irreversible impacts anticipated from the HCFC Phase II project as known at the time of appraisal. The preparation of appropriate safeguard instrument is detailed in the RPF. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area: There are no indirect, cumulative, or long-term adverse impacts caused by the project. 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. N/A 4. Describe measures taken by the borrower to address safeguard policy issues. Provide an assessment of Page 7 of 11 borrower capacity to plan and implement the measures described. Environment Although most sub-projects will only be confirmed from a long list of potential enterprises in different sectors, through subproject proposals to be prepared by application enterprises and appraised by the PMU during project implementation, considering alternatives with zero ODP and low GWP have been identified and some of them have been being used internationally, the generic Environmental Management Plans (EMPs), one for each sector, have been prepared by the Borrower. The World Bank has reviewed them and found acceptable. The objectives of the EMPs are to: i) ensure compliance with the applicable national, laws, regulations, standards, and guidelines; ii) ensure that there is sufficient allocation of resources on the project budget for implementation of EMP-related activities; iii) ensure that environmental risks associated with a project properly managed. The EMPs consist of the set of good practice mitigation measures, including the World Bank Group’s EHS guidelines, to address the sector-specific impacts, common construction related impacts which referred to as Environmental Codes of Practices (ECOP), and guidance on site-specific impacts and mitigation measures. The EMPs also include monitoring, and institutional arrangement for implementation, and the budgets for their implementation including for capacity building in project environmental management. Some specific mitigations measures are provided below: - As the alternative chemicals and gases are flammable, it will require changes of charging equipment and some production procedures during the construction and equipment installation phase: (i) Redesign the process, manufacture the prototype and test them; (ii) Modify the assembly line such as: change high – pressure pump, equip handheld leak detector, test pressure and drying; (iii) Inspect quality and testing; (iv) Issue certificates; (v) Process, operation maintenance and safety training; and (vi) Provide technical assistance from external experts. - During operation phase, the measures on precautions and chemical emergency response are requested. The enterprises to produce, use and storage those gases should prepare a document and submit to the Department of Industry and Trade before commission. For safety operation, the enterprises must also have the license of firefighting and prevention issued from the Department of Police. Environmental Safeguard Implementation, Monitoring, and Training. The PMU will be responsible for overall supervision and monitoring of the subproject including implementation of the subproject EMPs and will provide safeguard training to the subproject staff. The PMU will assign a safeguard specialist to assist in the coordination, supervision, and monitoring of safeguard implementation activities. For all subprojects, the participating enterprises are required to develop their own EMP with specific impacts and mitigation measures based on the sector generic EMP. The PMU will appraise the subproject proposals by visiting enterprises to ensure safety measures and equipment are included in the subproject proposals. Appropriate emergency preparedness and response measures should be in place when subprojects are completed. A due diligence review on occupational health and safety measures, fire and exposure risk will be conducted during the commission of subprojects and the early operation phase by the PMU. The Bank team will also selectively visit some subprojects to carry out safety review as well. Enterprises staff involved in the production, installation and services will be trained under the project. Social Resettlement Framework: A Resettlement Policy Framework has been prepared to guide relocation and potential land issues if any during preparation of the subproject proposals (during the overall project implementation stage). Social Safeguard Due Diligence Review: Due diligence review of the five already confirmed participating enterprises (4 in the AC sector and the XPS foam enterprise) were carried out during project preparation. It is confirmed that all the five enterprises complied with government laws and regulations on involuntary resettlement, there were no legacy issues pending to be solved. Page 8 of 11 Except for the five above confirmed participating enterprises, sub-projects will only be confirmed during project implementation, the Bank will review when and how the land was acquired or being acquired for the Industrial Zone and the enterprise relocation plan at the preparation stage of sub-projects. For each sub-project which require involuntary resettlement, if the land has been acquired before the grant agreement is signed, a due diligence review of the land acquisition process will be undertaken by the Bank team to confirm whether there is any legacy issues. The procedures for undertaking land due diligence review is presented as bellowed: a) PMU/MONRE submits to the Bank, a report containing general information on the actual status of the resettlement and compensation on the proposed project enterprises (within the selected IZ) as part of the package required for the subproject grant appraisal submission procedures. b) World Bank undertakes a due diligence (DD) of the resettlement and compensation in the selected area. The DD serves to confirm that involuntary resettlement and compensation in the proposed IZs is completed or substantially advanced. It will confirm that was undertaken following government norms and regulations and for general consistency with Bank policies and objectives. Additionally, it should confirm pending issues as per Grievances and Redress Mechanisms reports of the pertinent authorities, recommending actions to be followed. The DD report method used for gathering the information, includes desk review of documents issued by the Provincial, District and Communes levels, methods for gathering and analyzing the qualitative and quantitative information gathered in the field, results of the interviews with PAPs, and analysis of other pertinent issues and documents related to involuntary resettlement and land compensation on a case-by-case basis. Preparation of Abbreviated RAPs. An abbreviated RAPs (A-RAP) if applicable will be prepared for subprojects (as part of the sub-project proposals) to handle the relocation and potential land issues. Possible social issues if any outside resettlement will be reviewed as an annex to the generic EMP, as no significant social issues are expected. Monitoring. Based on the findings of the due diligence review or A-RAP, the Bank will monitor the involuntary resettlement and compensation that may be ongoing. The Bank will review the status of any pending compensation activities during implementation support missions. 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. The project key stakeholders are the beneficiary enterprises and relevant government agencies: the Ministry of Natural Resources and Environment (MONRE), the Ministry of Industry and Trade (MOIT), and the Customs. The stakeholders were consulted on the contents of the EMPs and RPF during their preparation. Another stakeholder consultation workshop was organized on November 17, 2016. Participants of the workshop were MONRE, MOIT, and Customs representatives, the selected enterprises, and representatives from some local governments. The feedbacks from the consultations have been taken into account in the preparation and incorporated into the final EMPs and RPF. The generic EMPs and RPF in Vietnamese were disclosed locally at the PMU website on November 21, 2016 and their English versions were disclosed through the Bank Operations Portal on November 21, 2016. The Appraisal Stage Integrated Safeguards Data Sheet of the project will also be disclosed through the Bank Operations Portal. . B. Disclosure Requirements Environmental Assessment/Audit/Management Plan/Other Date of receipt by the Bank 14-Nov-2016 Date of submission to InfoShop 12-Jan-2017 For category A projects, date of distributing the Executive Summary of the EA to the Executive Directors Page 9 of 11 "In country" Disclosure PHENVCTRY Vietnam 11-Jan-2017 Comments: Resettlement Action Plan/Framework/Policy Process Date of receipt by the Bank 30-Jun-2016 Date of submission to InfoShop 10-Jan-2018 "In country" Disclosure PHRESCTRY Vietnam 22-Dec-2017 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 PHCompliance OP/BP/GP 4.01 - Environment Assessment Does the project require a stand-alone EA (including EMP) Yes [] No [X] NA [] report? If yes, then did the Regional Environment Unit or Practice Yes [] No [] NA [] Manager (PM) review and approve the EA report? Are the cost and the accountabilities for the EMP Yes [] No [] NA [] incorporated in the credit/loan? PHCompliance OP/BP 4.12 - Involuntary Resettlement Has a resettlement plan/abbreviated plan/policy Yes [X] No [] NA [] framework/process framework (as appropriate) been prepared? If yes, then did the Regional unit responsible for safeguards Yes [X] No [] NA [] or Practice Manager review the plan? Is physical displacement/relocation expected? Yes [] No [] TBD [X] Is economic displacement expected? (loss of assets or access Yes [] No [] TBD [X] to assets that leads to loss of income sources or other means of livelihoods) PHCompliance The World Bank Policy on Disclosure of Information Have relevant safeguard policies documents been sent to the Yes [X] No [] NA [] World Bank's Infoshop? Have relevant documents been disclosed in-country in a Yes [X] No [] NA [] public place in a form and language that are understandable and accessible to project-affected groups and local NGOs? PHCompliance All Safeguard Policies Have satisfactory calendar, budget and clear institutional Yes [X] No [] NA [] responsibilities been prepared for the implementation of measures related to safeguard policies? Have costs related to safeguard policy measures been Yes [X] No [] NA [] included in the project cost? Does the Monitoring and Evaluation system of the project Yes [X] No [] NA [] include the monitoring of safeguard impacts and measures related to safeguard policies? Page 10 of 11 Have satisfactory implementation arrangements been agreed Yes [X] No [] NA [] with the borrower and the same been adequately reflected in the project legal documents? III. Approval Task Team Leader(s): Name:Qing Wang,Katelijn Van den Berg Approved By: Practice Manager/Manager: Name: Christophe Crepin (PMGR) Date: 11-Jan-2018 Page 11 of 11