The World Bank Maputo Metropolitan Area Urban Mobility Project (P175322) Appraisal Environmental and Social Review Summary Appraisal Stage (ESRS Appraisal Stage) Public Disclosure Date Prepared/Updated: 04/14/2022 | Report No: ESRSA02113 Apr 14, 2022 Page 1 of 18 The World Bank Maputo Metropolitan Area Urban Mobility Project (P175322) BASIC INFORMATION A. Basic Project Data Country Region Project ID Parent Project ID (if any) Mozambique AFRICA EAST P175322 Project Name Maputo Metropolitan Area Urban Mobility Project Practice Area (Lead) Financing Instrument Estimated Appraisal Date Estimated Board Date Transport Investment Project 4/4/2022 6/1/2022 Financing Borrower(s) Implementing Agency(ies) Republic of Mozambique Maputo Metropolitan Transport Agency (AMT), Maputo City Council, Matola City Council Public Disclosure Proposed Development Objective The Project Development Objective is to improve mobility and accessibility along selected corridor in the Maputo Metropolitan Area. Financing (in USD Million) Amount Total Project Cost 250.00 B. Is the project being prepared in a Situation of Urgent Need of Assistance or Capacity Constraints, as per Bank IPF Policy, para. 12? No C. Summary Description of Proposed Project [including overview of Country, Sectoral & Institutional Contexts and Relationship to CPF] The Maputo Metropolitan Area is entering a transition phase as the urban area has grown from Maputo city into neighboring Municipalities and Districts. The adjoining municipality of Matola has almost doubled its population in the past ten years, with much of the growth taking place in areas that are not yet served with paved roads. Urban density has declined, and the new growing areas lack a complete, integrated roadway network of sufficient capacity to support public transport. The attempts by Government to coordinate metropolitan area planning and improve Apr 14, 2022 Page 2 of 18 The World Bank Maputo Metropolitan Area Urban Mobility Project (P175322) public transport operations for the growing area are at a nascent stage and require considerable strengthening to sustain the initial efforts. To sustain Government’s efforts, the project would focus on: a) strengthening institutional and governance framework; and b) financing integrated and comprehensive package of investments to improve public transport and road infrastructure. Strengthening governance and institutional framework will focus on: (i) clarifying the roles of Municipalities and Districts in relation to governance of AMT and developing comprehensive strategies; and (ii) developing a common understanding of ‘coordination’ and ‘jurisdiction’ as mentioned in the AMT Decree; and (iii) strengthening organizational and technical capacity at national, metropolitan, municipal and local government levels. The project will support improvements of the common framework to regulate public transport service at a Metropolitan level, in an incremental basis. The investment package would support an integrated approach to respond to the growing challenges in the urban transport sector to foster changes in the way the city is growing from a congested, vehicle-oriented city to a resilient, people-oriented city, where safe walking and public transport are at the core of the metropolitan vision, and with a focus on vulnerable groups such as low-income residents, women and PWD. The focus will be on one of the most congested and heavily used corridors in the city, which are adversely impact by climate change and result in periodic flooding and road damage. The project would finance Bus Rapid Transit (BRT) with operations, service and business plans to support safe, secure, reliable and affordable transport for all residents along the corridor coupled with integrated planning in the catchment area, improvements to road infrastructure, sidewalks, NMT infrastructure, street lighting, traffic management, parking management. Support will be provided to implement integrated electronic fare to enable Public Disclosure seamless mobility and protect revenue collection; install ITS for traffic flow management, public information systems at bus stations, traffic signal synchronization and prioritization for public transport at intersections and intermodal terminals. The specific interventions will be designed in consultation with a diverse group of public, private, and civil society stakeholders. D. Environmental and Social Overview D.1. Detailed project location(s) and salient physical characteristics relevant to the E&S assessment [geographic, environmental, social] The proposed project aims to improve urban mobility that supports upgrades in the metropolitan urban transport system, support the design of safer urban transport, invest in urban infrastructure, and contribute to change the way the metropolitan area is growing: from a congested, vehicle-oriented city to a resilient, people-oriented city, where greener modes, such as non-motorized transport and public transport, are at the core of the metropolitan vision. The project also aims to reinforce infrastructure investments with digitalization and institutional strengthening activities that will focus on transparency, sustainability, and capacity building to bolster the urban transport sector. The proposed project will be implemented in the Maputo Metropolitan Area (MMA), which is located in the South of Mozambique, specifically on the margins of Maputo Bay. The MMA composed of Maputo City, Matola city, Boane village and Marracuene District, has an area of approximately 2159 km2 and a population of approximately 3 000 000 inhabitants (Census 2017). The expansion of the MMA into new neighboring municipalities and districts is taking place in areas that are not yet served with paved roads and lack a complete and integrated roadway network of sufficient capacity to support public transport services. The corridor comprises a core section of 19 km extending from Anjo Voador in the Maputo City Centre to Praça da Juventude in Magoanine and to Praca Missao Roque by Praça dos Apr 14, 2022 Page 3 of 18 The World Bank Maputo Metropolitan Area Urban Mobility Project (P175322) Trabalhadores, Av. Acordos de Lusaka, Av. das Forças Populares de Libertação de Moçambique (F.P.L.M.), Av. Julius Nyerere and Ave Maria Lurdes Mutola. This corridor carries passengers from places further away including Matola City, Marracuene Village, and the popular terminals of Matola Gare, Zimpeto and Albazine. The BRT service seeks to introduce direct service routes that extend beyond the “core” corridor to connect to other major terminals in Maputo, Matola and Marracuene. Nonethless, the exact location, layout and design of the stations will be further defined in the ongoing detailed engineering studies. The population density in Maputo is substantially higher than other cities/districts in Greater Maputo. Furthermore, the population in Greater Maputo is also expanding toward the west with about 830,000 people living in Matola City that is undergoing industrial development. The municipality of Matola is the largest municipality in the Country in terms of number of inhabitants (1.7 million according to the 2017 Census). Maputo is the political, commercial, and industrial center of Mozambique. It is the most affluent area in Mozambique. The central area of Maputo corresponds to a planned city with square blocks and wide avenues. It also hosts a major port of regional importance that serves parts of South Africa, Swaziland, Zimbabwe and Botswana as well as Mozambique itself. Metropolitan Maputo is comprised of the neighboring cities of Maputo, Matola, Marracuene and Boane. Significant population growth is forecast for the Metropolitan area - increasing from 3.1 million in 2021 to 4.7 million in 2035. The public transport system is mainly comprised of bus and minibus routes, with a small number of rail and ferry services. The bus and minibus sector is fragmented across a large number of vehicle owners that are coordinated through associations and cooperatives. There are also municipal bus operators in Maputo and Matola, which currently operate a relatively small fleet compared to the private sector, and a formal operator called MetroBus Public Disclosure which operates some commuter rail services and a handful of connecting bus services. There are several modes of transport used in the city including public buses and private vehicles. About 14.5 percent of households own vehicles in the city which means that there is an overwhelming dependence on public and other sources of transport. Surveys undertaken during project preparation indicate that 71% of those formally employed use public while 56% of those employed informally use public transport. 32% of children interviewed reported using public transport for school commute. Much of the land in Marracuene District and Boane City is currently agricultural or comprises of natural areas, and significant population growth has not taken place yet. The informal nature of urban settlements is in itself a threat to the environment. Major environmental and social challenges include garbage collection, poor roads, poor drainage, and coordination of stakeholders to put in place sectoral reforms to the public transport systems The informal settlements that dominate the city are also in a poor state, with many located near, or in, floodplains. Most of the capital’s inhabitants are thus at risk of natural hazards like floods and landslides. Tree logging and small-scale agriculture magnifies this vulnerability, adding erosion and landslides to the risks. Additionally, lack of solid waste management, proper drainage and poor sanitation makes the communities vulnerable to flooding and water borne diseases. Key Biodiversity Areas (KBA) include the protected mangrove areas of Maputo estuary along the coastal area of Maputo Bay, the wetland areas along the water courses of Inkomati river in Marracuene, Matola river in Matola City and Infulene river in Maputo city. These ecological sensitive areas located around the proposed the BRT routes. Apr 14, 2022 Page 4 of 18 The World Bank Maputo Metropolitan Area Urban Mobility Project (P175322) Overall, the project is expected to have a positive impact on traffic by promoting public mass transportation. Additionally, the project will adopt an integrated approach to the design of facilities and emphasize the importance of focusing on the special needs of vulnerable people, including women and Persons With Disabilities (PWDs). However, some negative impacts may be caused temporarily during construction and operations of BRT network. The project site is in an urban area, posing low to moderate risks to natural habitats and its associated ecosystem. There are no cultural heritage sites likely to be affected by the proposed project interventions. Nonetheless, the borrower will ensure that public facilities shall be preserved or restored after construction works of BRT. In addition, the BRT investments will also have a strong focus on climate change resilience, especially considering flood risk management. Climate resilience measures will produce an array of co-benefits for the residents including improved aesthetics, ample recreational areas, protection of biodiversity, etc. D. 2. Borrower’s Institutional Capacity The Ministry of Transport and Communications (MTC) will be the supervisory ministry. The MTC has the overall responsibility for policy direction, coordination, and supervision for all modes of transport in the Country. The AMT (Agencia Metropolitana de Transportes) will act as the main implementing agency, under the technical guidance of the MTC. AMT is a public entity whose main responsibility is to plan and manage collective public transport services across the Maputo Metropolitan Area, through coordination with the Municipalities and Districts who have mandates within their areas. A Project Coordination Unit (PCU) will be set up in AMT to technically supervise and coordinate the project’s activities as well as perform all operationally related tasks such as M&E, financial management and procurement, and ensure coordination across municipalities and institutions. The PCU will also coordinate and manage overall Environmental, Public Disclosure Social, Health and Safety (ESHS) aspects in close collaboration with the Project Technical Units (PTUs). The PTUs will be set up in AMT (PTU1), Maputo (PTU2) and Matola (PTU3); one technical unit in each of these three institutions; to lead the technical implementation of different components including overseeing environmental and social (E&S) risk management. The PTUs will report to the project technical coordinator (PTC) that is placed in the PCU. The technical units will also provide technical support to PCU in procurement tasks related to preparing terms of references and conducting technical evaluations. At PCU level (PTU1), the project has already engaged one (1) environmental specialist and one (1) social and resettlement specialist and the recruitment process of a SEA/SH specialist is underway. Likewise for the PTU2 at Maputo Municipality council one environmental (1) and one (1) social specialist have already been hired under the Maputo Urban Transformation Project (MUTP - P171449) while the position for one (1) SEA/SH Specialist is still under recruitment. A PTU3 will be set up at Matola Municipality council and will hire and engage one (1) environmental and one (1) social and resettlement specialist and one (1) SEA/SH officer. All these positions shall be recruited within 120 days after project effectiveness and maintained throughout project implementation. MTC has had few World Bank funded operations, hence their capacity to manage E&S risks is limited, particularly for high risk projects. On the contrary, Maputo Municipality Council has longstanding experience of E&S risk management, and it is currently implementing the MUTP (171449) which has been rated satisfactory, since its effectiveness in 2020. E&S staff at Maputo Municipality will be essential in the ESF knowledge dissemination across different project technical units. Notwithstanding, detailed institutional arrangements for operating the BRT and other public transport facilities will be further defined in the site specific ESIA as many impacts will arise during project operation needing proportionate implementation arrangements. Apr 14, 2022 Page 5 of 18 The World Bank Maputo Metropolitan Area Urban Mobility Project (P175322) Technical support from the Bank will be needed to ensure adequate implementation of the capacity building program as presented in the ESMF and ESCP aimed at strengthening PCU ability to manage E&S risks inherent of this project, specifically in aspects such, as land acquisition and resettlement in urban contexts, labor right issues, road safety management, effective and functional Grievance Redress Mechanism (GRM), GBV/SEA/SH risks, gender and social inclusion and disability. Support from the Bank will be needed to implement the capacity during the project. Further technical support will be made available as required to prepare subproject level instruments and studies. Finally, the World Bank will make an extra supervision effort and maintain a close working relation with PTUs. II. SUMMARY OF ENVIRONMENTAL AND SOCIAL (ES) RISKS AND IMPACTS A. Environmental and Social Risk Classification (ESRC) High Environmental Risk Rating Substantial The project Environmental risk is rated as “Substantial” due to project’s likely environmental risks and impacts combined with the current borrower’s fragmented and challenging implementation arrangement and limited untested E&S risk management capacity under the ESF. The scale of the project will be along selected corridors in the Maputo Metropolitan Area (MMA) and in strategic access streets to neighborhoods from the BRT corridors. While technical details for the proposed interventions have not yet been defined, the project is expected to generate direct, indirect and cumulative environmental impacts and risks. These risks and impacts are expected to be significant in magnitude and spatial in context, albeit temporary, predictable and in most cases reversible. Environmental risks and impacts, include: i) soil erosion and degradation due to earthworks for construction Public Disclosure rehabilitation; ii) soil and surface water pollution from construction works and campsites; iii) dust and noise emissions from construction vehicles leading to impacts on water and air quality that could pose significant public health risks, iv) generation of hazardous and non-hazardous waste, v) occupational health and safety concerns to contracted workers. Since proposed investments will occur in urban settings with high densely populated neighborhoods and congested areas, there are also substantial community health and safety that could lead to increased traffic safety issues, accidents with pedestrians, vehicles and other road users, public nuisance, as well as risks associated with the integrity of infrastructures due to natural hazards. In addition, proposed project activities will generate indirect and cumulative risks and impacts that will lead to: (i) changes on ambient conditions such as the incremental contribution; (ii) pressure on hydrological and water resources due to multiple extraction or increased demand (iii) increased traffic congestion and accidents along during the BRT network construction; (iv) induced urban expansion into agricultural areas; (v)increased pressure on natural habitats from extraction of construction materials in ancillary facilities (vi) increased migration that may lead to increased pressure on other public resources, such as parks, recreational areas and green infrastructures. The project will finance a series TA activities, mainly under component 1 and 2, which under the ESF classification comprise: (i) Type 1 TA - Development of the BRT concept and detailed design; Type 2 TA – support regulatory and institutional reforms, the formulation of comprehensive planning strategies, guidelines, and frameworks for professionalization of formal and informal operators and Type 3 TA – to support planning and establishing of an integrated public transport system and to support transport operators to develop their organizational and operational capacity. When implemented, the outcome of Type 1 TA activities to support the development of the BRT concept and detailed designs will lead to substantial risks and impacts on people and on the environment relevant to the ESS’s 1-6, 8 and 10 such as soil, air, water resources pollution and degradation, OHS risks, community health and safety risks and contribute for the generation of hazardous and non-hazardous waste. Type 2 - TA activities related with the proposed regulatory Apr 14, 2022 Page 6 of 18 The World Bank Maputo Metropolitan Area Urban Mobility Project (P175322) reforms in the sector and drafting of strategic policies and plans may lead to moderate downstream environmental risks when implemented through future investments that will require adequate assessment of environmental implications once detailed scope of such reforms are plans are known. Notwithstanding, such impacts are expected to be mostly temporary, predictable, site specific and readily manageable. On the other hand, Type 3 – TA activities are expected to generate minimal or negligible environmental risks and impacts. Social Risk Rating High The Project Social Risk Rating is assessed as “High” due to civil works in an urban context under Components 2 and 3 which are expected to result in involuntary resettlement, economic displacement and temporarily induced impacts on public and private assets, including disruptions and access restrictions to residents and local economic activities in the Maputo Metropolitan Area. This could also impact the livelihoods of street vendors and other vulnerable groups dependent on informal livelihoods in the city . Temporary livelihood impacts may also take place due to access restrictions, on-site facilities for workers and site offices. Civil works are likely to require temporary use of land for material and machinery storage and could also impact assets during construction. The exact extent of land to be acquired and its resettlement impacts are not yet clear but due to the project’s urban setting, these impacts are expected to be high. The proposed interventions under the Project are expected to use contracted, direct, and primary supply workers under Components 1, 2 and 3. Unless mitigation measures are in place, there is a risk of working conditions not being compliant with local laws and ESS2, use of child and forced labor and increased risk related to Sexual Exploitation and Abuse/Sexual Health (SEA/SH). The presence of labor close to communities, increase in disposal income for workers together with low levels of awareness on SEA/SH can contribute to an increase in SEA/SH risks. Since the project will take place in an urban area with relatively better access to SEA/SH support services, the SEA/SH risk is rated as "substantial". Further, the risks of SEA/SH are also relevant during the Public Disclosure operational stage as the Social Assessment for the project indicated that 95% of women feel unsafe either during travel and during the process of accessing transport. Project activities for Components 1, 2 and 3 have the potential to result in stakeholder conflicts that can jeopardize project implementation due to institutional capacity to implement stakeholder engagement initiatives that are open, transparent and inclusive, allowing meaningful consultation that includes vulnerable groups. The risk of social conflict is also possible given an urban environment with multiple stakeholders who can potentially face negative impacts. Residents and users of areas where civil works will take place can come into conflict with labor and face issues during construction that can increase hostility towards the project particularly if they are not informed and consulted about potential impacts, timing of civil works and changes in access. Road users can face longer routes due to diversions and restrictions due civil works which could potentially result in traffic accidents. Marginalized groups such as women, Persons with Disabilities PWDs), elderly, illiterate and other groups can also face marginalization and exclusion unless impacts on them are not taken into account during project implementation. In particular, such groups may continue to face access restrictions if their needs are not addressed to design accessible and safe public transport during the operational phase. Additionally, Technical Assistance (TA) activities under Components 1 and 2 can lead to conflicts among stakeholders due to lack of transparency in project design and hiring processes. The limited ability of the Borrower to manage social risks and impacts also contributes to the risk rating being high. Components 2 and 3 under the project include civil works have the potential to impact cultural property, especially in downtown Maputo where several old buildings are located. Any impacts on cultural property could also potentially lead to loss of heritage and social conflicts. These risks may be exacerbated within an urban context where there are multiple stakeholders and users of transport, roads and other infrastructure. Apr 14, 2022 Page 7 of 18 The World Bank Maputo Metropolitan Area Urban Mobility Project (P175322) B. Environment and Social Standards (ESSs) that Apply to the Activities Being Considered B.1. General Assessment ESS1 Assessment and Management of Environmental and Social Risks and Impacts Overview of the relevance of the Standard for the Project: ESS1 is relevant since the project will support investments under components 1, 2 and 3 for the construction and supervision of BRT and infrastructure in the selected BRT “core”, feeder corridors. The proposed project activities are expected to generate direct, indirect, and cumulative adverse environmental risks and impacts, mainly related to Occupational Health and Safety (OHS) risks to contracted workers during the construction phase, as well as community health and safety risks during both construction and operations phases. Additional anticipated construction phase risks and impacts include degradation of habitats, due to loss of vegetation and soil erosion, soil and surface water pollution, dust, and noise emissions, reduction on water quality and quantity that could pose significant public health concerns, generation and disposal of construction waste, occupational health and safety concerns to contracted workers as well as community health and safety risks caused by public nuisance, increased road traffic and induced migration. Increased pressure on natural habitats in ancillary facilities may occur, due to the extraction of construction materials in borrow-pits and quarries. In addition, health risks associated with the spread of COVID-19 is likely to be a common risk across the project. Proposed interventions, mainly under components 2 and 3 related with BRT infrastructures and investments in non-motorized infrastructures in strategic access streets to neighborhoods, are likely to generate significant indirect and cumulative effects on the nearby biophysical and social environment. Public Disclosure In order to manage environmental and social risks associated with the project and given the fact that detailed technical information of the proposed investment is not known at this stage; the Borrower prepared an Environmental and Social Management Framework (ESMF) to identify and address environmental and social risks and impacts and to propose relevant mitigation measures in a manner that is consistent with ESSs1-6, 8, and 10. The ESMF was consulted upon, and it will be disclosed prior to project appraisal completion. The ESMF provides an overview of the project and its components, the applicable legislative and regulatory frameworks and policies, an overview of the baseline conditions and a summary of key anticipated environmental and social impacts including on any Associated Facilities in a manner proportionate to its control or influence over the Associated Facilities to enable the project to achieve objectives materially consistent with the ESSs. It also provides mitigation and monitoring measures and a screening tool for assessing and classifying impacts at sub-project level and guidance for the preparation of sub-level project-specific Environmental and Social Assessment (ESIA) and complementary Environmental and Social Management Plans (ESMPs), sub-level project specific Occupational Health and Safety (OHS) plans, Community Health and Safety (CHSP), Waste Management Plans (WMP) Traffic Management Plan (TMP), Labor related measures (LMP), Cultural Heritage Plan and Chance Finds procedure during the implementation phase. The ESMF provides guidelines for the preparation of the CERC – ESMF. All CERC-funded activities are subject to World Bank ESSs and will make use of the original Project's E&S assessments, ensuring that risks and management measures are known in anticipation of an emergency response. sub project exclusion list included in the ESMF shall be implemented by the Recipient ensuring that all subprojects that are not sustainable in the short, medium and long term due to their risks, location or because they represent risks and impacts that cannot be mitigated or compensated will not be financed by the project. The Borrower will prepare at least one site-specific ESIA/ESMP for entire BRT route and other site-specific ESIA/ESMP for BRT complementary infrastructure in concert with the detailed design contracts. The ESMF also contains detailed guidance on the conduct of a Cumulative Impact Assessment (CIA) Apr 14, 2022 Page 8 of 18 The World Bank Maputo Metropolitan Area Urban Mobility Project (P175322) as part of the preparation of subproject level ESIAs. In addition, a Strategic Environmental and Social Assessment (SESA) will be carried out to identify and assess the potential impacts of the proposed project related technical designs, institutional and regulatory reforms of urban transport at national, metropolitan, municipal, and local government levels, while formulating alternatives and outlining mitigation measures in a manner consistent with ESS. An Environmental and Social Commitment Plan (ESCP) setting out the environmental and social commitments for the project was prepared by the borrower. The ESCP includes aspects such as the need for an environmental and social assessment, such as CIA and sub-project specific requirements such as ESIA, ESMP, RAP, OHS Plan, including a SESA, which shall be developed in consultation with stakeholders, and approved and disclosed by the Bank. Social risks of the project include resettlement (both physical and economic displacement) due to civil works, as well as labor issues, SEA/SH, public health and communicable diseases, social conflict and marginalization during the implementation stage. Land acquisition on permanent and temporary basis will be required for civil works related to Components 2 and 3 and will lead to physical displacement (both temporary and permanent) and impacts on livelihoods particularly on informal vendors, transport operators and small businesses. Access restrictions are also expected during the construction phase. A Resettlement Policy Framework has been prepared to provide guidance on the preparation of site-specific Resettlement Action Plan/s and/or Livelihood Restoration Plans (LRPs). RAPs will be prepared for each sub-project and implemented before commencement of civil works. LRPs will be prepared either as part of RAPs or as standalone documents depending on the nature and timing of impacts. Labor related impacts include working conditions not in line with ESS2 and local laws, use of child labor and/or forced labor and increased risk of SEA/SH. Labor Management Procedure (LMP) has been prepared to ensure that all Public Disclosure workers are provided working conditions in line with Mozambican laws and ESS2. The LMP includes a worker’s GRM. Contractors will be required to ensure that labor aspects are included in C-ESMPs. The risks of SEA/SH have been assessed through a Risk Assessment undertaken as part of the ESMF. The SEA/SH Risk Assessment includes an assessment of factors leading to an increase in risk, presents mitigation measures aimed at labor and community levels and provides guidance on the design of a SEA/SH sensitive Grievance Redress Mechanism. A Social Assessment has been drafted to analyze issues in safe, affordable, and reliable transport for poor, marginalized, and vulnerable groups, as well as an assessment of Citizen Engagement measures that can be strengthened or improved under the Project. The SA, defined in specific TORs, was aligned with the Bank’s Directive on Addressing Impacts on Vulnerable Individuals and Groups, and especially included low-income riders and informal transport sector providers. The SA included PWDs, women, elderly, children and explored issues related to safe and reliable access to public transport for these groups. Key findings from the SA showed that (i) public buses are used by people belonging to various ages and mostly by those in formal and informal employment including women (ii) 54% women respondents do not feel it is easy to travel by bus mainly due to lack of availability of buses, congestion at peak times and poor condition of access roads as the main factors (iii) 56% of Persons with Disability stated that they were given priority in lines and boarding buses but that the buses were not designed for their easy access and use (iv) elderly reported difficulty in using stairs on buses and lack of seats during rush hours (v) about 48% of women and 47% of male respondents did not feel protected from sexual harassment on buses mainly due to overcrowding during rush hours, lack of policing and lack of lighting. T The SA also indicated that no systems of public consultation or grievance redress are functional or available in the AMT and that sexual harassment cases are rarely reported. Using this information, the the ESMF and other instruments have proposed inclusive consultations during the design and implementation phase, ensuring universal access and making the public transport system safe for all types of users. A Apr 14, 2022 Page 9 of 18 The World Bank Maputo Metropolitan Area Urban Mobility Project (P175322) Stakeholder Engagement Plan outlines the requirements for consulting all relevant stakeholders and includes a GRM. The SEP provides a design of community consultations during the implementation phase which will need to take place at multiple levels and include marginalized groups. The project will finance a series of TA activities, mainly under component 1 and 2. When implemented, the outcome of Type 1 TA activities to support the development of the BRT concept and detailed designs will lead to substantial risks and impacts on people and on the environment such as soil, air, water resources pollution and degradation, OHS risks, community health and safety risks and contribute for the generation of hazardous and non-hazardous waste. Type 2 - TA activities related with the proposed regulatory reforms in the sector and drafting of strategic policies and plans may lead to moderate downstream environmental risks when implemented through future investments that will require adequate assessment of environmental implications once detailed scope of such reforms are known. Type 3 – TA activities are expected to generate minimal or negligible environmental risks and impacts. The ESMF includes guidelines for the preparation of an assessment of the risks and impacts of all TA activities under the SESA. ESS10 Stakeholder Engagement and Information Disclosure ESS10 is relevant. Key stakeholders relevant to public transport consist of MTC, Municipalities of Maputo, Matola and Boane, AMT, Surface Transport Regulatory Body (‘INATTER’), the National Port and Railways Company (‘CFM’), FTC, Municipal Bus Enterprises, privately owned bus Cooperatives operating in Greater Maputo, minibus Associations, FEMATRO, and the private railway operator (Metrobus). Activities in all three components have the potential to result in stakeholder conflict that could jeopardize project's implementation. Therefore, the two components will Public Disclosure maintain open and transparent engagement between the borrower and the project stakeholders throughout the project cycle. Stakeholder engagement activities for Component 1 will be implemented by the MTC. These activities are mainly related to institutional strengthening, policy, and strategy development. The implementation of activities under this Component will require a robust communication and public outreach strategy. While MTC has a long-standing history of managing stakeholders within the transport sector in Maputo and beyond, the entity has no prior experience with World Bank funded project under ESF or in urban settings. A Social Assessment (SA) was prepared by the project that provided an assessment of citizen feedback and grievance redress mechanisms currently in place. The SA showed that there is no clear and efficient communication and complaint management system that guarantees the involvement of citizens in the decisions that are made regarding public transport. Further, currently there is no GRM in place in AMT. The Project will establish these systems in AMT. The Project has prepared a SEP that maps out various stakeholders and sets out strategies on how to engage with them throughout the project life cycle, allowing for meaningful consultation in a participatory manner that includes the involvement of vulnerable groups; how information related to the project will be shared at different levels; and stakeholder feedback and concerns will be considered during project design and implementation. It also includes guidance on how the project will manage grievances through the implementation of the project Grievance Redress and Dialogue Mechanism (GRM) that is sensitive to GBV/SEA/SH risks. Different means of consultation are outlined in the SEP due to the current COVID-19 situation, aligned with the national regulation and the World Bank guidelines. Relevant stakeholders for this component will include, public and private transport companies, transport associations, municipalities, local governments, users of public transport, including vulnerable groups, informal Apr 14, 2022 Page 10 of 18 The World Bank Maputo Metropolitan Area Urban Mobility Project (P175322) operators of public transport, etc. As part of the SEP, a Public Consultation Report was prepared with a total number of 45 public meetings, 41 key informant interviews, all conducted over a two weeks period in January 2022, with the Interested and Affected People (I&Aps) in key areas of sections of the N1 identified for the project. The meetings were held in Inhambane, Sofala, Zambezia, Nampula and Cabo Delgado Province. The main findings from consultations highlighted the need for continued inclusion of stakeholders, risk of SEA/GBV/SH, design of civil works to be user friendly, promoting safety and mitigating impacts on livelihoods. This feedback has been included by designing a robust SEP with consultations planned all stakeholders including vulnerable groups, inclusive design of civil works including to provide universal access, a GBV Risk Assessment and livelihood restorations measures. Stakeholder engagement activities under Components 2 and 3 will be implemented by the Maputo Municipality. Financing integrated and comprehensive package of investments to improve public transport in the Metropolitan Area of Maputo will require systematic, inclusive, and intensive engagement of stakeholders to execute the proposed investments successfully and effectively. Stakeholders to be consulted and engaged include the MTC, Municipalities of Maputo, Matola and Boane, AMT, Surface Transport Regulatory Body (‘INATTER’), the National Port and Railways Company (‘CFM’), FTC, Municipal Bus Enterprises, privately owned bus Cooperatives operating in Greater Maputo, minibus Associations, FEMATRO, the private railway operator (Metrobus) and users, which include vulnerable groups such as women, illiterate people, People with Disabilities and elderly The Maputo Municipality has a long history and experience of stakeholder/ citizen consultation and engagement mainly on participatory budgeting and decentralized local governance process. Currently existing engagement structures are being utilized under another World Bank funded project under ESF- Maputo Urban Transformation Project. Public Disclosure The Project’s Stakeholder Engagement Plan also covers activities under Component 2 that will be implemented by the Municipality.. The development of the SEP takes stock of current developments regarding the Maputo Urban Transformation Project and other relevant initiatives by the Municipality. The SEP particularly outlines means of consulting vulnerable and marginalized groups in stakeholder consultations including transport operators “My Love” during the project cycle. The SEP will be disclosed alongside the ESMF, RPF, and ESCP prior to project appraisal. B.2. Specific Risks and Impacts A brief description of the potential environmental and social risks and impacts relevant to the Project. ESS2 Labor and Working Conditions ESS2 is relevant. The Project will use direct, contracted, and primary supply workers and will need to comply with Mozambique's legislation and the requirements of ESS2 for each category of workers. Direct workers will include consultants and technicians hired to support the implementation of the project for both the PCU and PTUs. The expected number of direct workers is approximately 20 but the number of contracted workers is not yet known. Community workers will not be hired or involved in project activities. The borrower has prepared a Labor Management Procedure (LMP) for the project that will apply to all type of workers (direct workers, contracted workers, and primary supply workers). . Critical components of the LMP also include GBV/SEA/SH issues in connection with labor use. LMP contains relevant risks, mitigation measures, including Apr 14, 2022 Page 11 of 18 The World Bank Maputo Metropolitan Area Urban Mobility Project (P175322) a basic Code of Conduct, mapping of resources, awareness measures, and procedures for further assessment at the subproject level. Other relevant elements of the LMP relating to contracted workers include: - OHS, working conditions, and GRM for workers that is GBV/SEA/SH sensitive which will be included in the contractor's ESMP; and OHS Plan and COVID and infectious disease prevention/response for direct workers. Bidding Documents will make a clear reference to these aspects to ensure that selected contractors adhere to the ESS2 requirements and principles. The LMP includes provisions to ensure fair wages in line with local legislation and provide contractual hiring of workers (both male and female), adequate payment for overwork and other measures. While the project aims to use local labor and no labor camps are anticipated, should the hiring of workers from outside the local area be required (especially for purposes of the installation of specialist technical equipment), worker accommodation and influx will need to be managed in line with ESS2 (and ESS4). Occupational health and safety risks associated with the construction and operation of BRT system and associated infrastructure include (i) physical hazards from repetitive exposure to work activities (noise, electrical and vibration) that can cause accidents and injuries; (ii) chemical hazards due to chronic repetitive exposure to toxic, corrosive, sensitizing or oxidative substances; (iii) biological hazards from exposure agents, to pathogens and vectors that can cause human disease, mainly at ancillary facilities. The borrower has included in the ESMF, measures for the identification and mitigation of project Occupational Health and Safety (OHS) risks to contracted workers associated with the construction, rehabilitation, operation and maintenance BRT and associated infrastructures to be financed under Component 2 and 3, in line with the Good International Industry Practices (GIIP) and the World Bank Group General Environmental, Health and Safety Guidelines (EHSG), specifically the Industry Sector EHSG for Toll Roads. To ensure health and safety of contracted workers during the construction and operational phases of the project, the Public Disclosure site-specific assessments, e.g. ESIA/ESMPs will assess OHS risks to contracted workers and an OHS Plan in line GIIP will be required to be prepared as part of the Contractors-ESMP (C-ESMP). ESS3 Resource Efficiency and Pollution Prevention and Management ESS3 is relevant. In accordance with ESS3 the project should avoid or minimize project-related emissions and generation of nonhazardous waste and promote the sustainable use of energy. The proposed project will reduce greenhouse gas (GHG) emissions by replacing more polluting transport modes to modal shift lower carbon transport modes like Bus Rapid Transit (BRT) and non-motorized transport (NMT) thus, improving public transport capacity and efficiency. Overall, the project is estimated to lead to a total net emissions reduction of 236,075 tons of CO2, over the economic life of the project. The project is not expected to lead to significant water, raw material, or energy use. Notwithstanding, proposed activities related with the construction and operation of BRT system and investments in non-motorized infrastructures in strategic access streets to neighborhoods may generate some adverse impacts related to disposal and management of waste during the construction phase, occupational health and safety of workers and pose significant public health concerns due to nuisance related to air and noise and dust emissions. Operation and maintenance of BRT vehicles and infrastructures may potentially lead to surface water and land contamination, due to oil spillage or releases into nearby watercourses or land nearby the worksites and CO2 emissions, albeit expected at low scale. In addition, there may be a need to explore ancillary facilities such as Apr 14, 2022 Page 12 of 18 The World Bank Maputo Metropolitan Area Urban Mobility Project (P175322) borrow-pits and quarries from which construction materials may be sourced during construction phase. Type 1 TA activities to support the development of the BRT concept and detailed designs will lead to substantial risks and impacts on people and on the environment such as soil, air, water resources pollution and degradation, OHS risks, community health and safety risks and contribute for the generation of hazardous and non-hazardous waste. Noise and Traffic: During mobilization, construction, demobilization and operation phases, noise and traffic are generated from the use of construction machinery and vehicles/fleets movements. As the construction sites are located in the urban and peri areas, noise should be managed by proper arrangement of working hours as necessary to minimize noise to surrounding public areas. The ESIA will assess impacts to nearest sensitive receptors and propose mitigation measures to minimize and manage the noise levels. Management of air pollution: Mainly during construction phase, dust will be generated by construction activities (e.g. excavation, heavy equipment operation) and from operation of heavy vehicles and machinery During the operational phase, the fleets of vehicles will be properly maintained to minimize air pollution. The air pollution will affect not only the workers but also people living within the proximity of the construction sites and corridors. The implementation of mitigation measures such as dust suppression and regular vehicles maintenance, regulation of vehicle speed will be applied to minimize the impact of air emissions during mobilization, construction, demobilization and operation phase. The ESMF provides guidance for subproject level ESIA/ESMPs which will include an assessment of the available regulated capacity of licensed disposal facilities for generated waste streams, including hazardous wastes. A Waste Management Plan (WMP)and water harvesting technological plan will be prepared as part of C-ESMP to include and Public Disclosure adopt measures specified in the WBG General EHSGs in line with GIIP including to the extent technically and financially feasible and in manner proportionate to the projects impacts and risks. The WMP will include an assessment of the presence of trash around transportation hubs develop measures to increase community education and awareness for proper disposal facilities and coordinated trash collection and management in the BTR and related facilities. Moreover, sub-project specific ESMPs will include measures for addressing soil and water pollution, dust and noise emission, management of hazardous and non-hazardous waste and closure of any ancillary facilities such as borrow-pits and quarries during the construction phase. ESS4 Community Health and Safety ESS4 is relevant to the project. The Project is required to include assessments of risks and impacts of project activities to health and safety in project affected communities in all phases of the project cycle. Risks and impacts could relate to the design and safety of infrastructure, traffic, and road safety (particularly during construction and operation), or community exposure to nuisance and public health issues including assess the presence of trash around transportation hubs to develop measures to increase community education and awareness for proper disposal facilities and coordinated trash collection and management along the BTR corridors and in the strategic access streets to neighborhoods from to the BRT corridors. Since the project will take place in an urban setting and downtown areas of high population density, risks and impacts on the community may also include security, and emergency situations such as increased accident to road users and pedestrians due to increased and congested traffic and community exposure to nuisance and public health issues related with air and water sources pollution. There also risks related to BRT infrastructures integrity against natural hazards exposure. Consequently, the borrower prepared an ESMF Apr 14, 2022 Page 13 of 18 The World Bank Maputo Metropolitan Area Urban Mobility Project (P175322) containing detailed guidance for subproject level ESIAs/ESMPs preparation, including obligations for Contractors to prepare site-specific Community Health and Safety Plans (CHS Plans) as part of the C-ESMP and maintain qualified staff for its implementation. The construction of BRT system and associated infrastructures will require the movement of construction equipment and materials potentially through an urban setting and congested downtown areas, resulting in possible road and pedestrian accidents. Vibration from construction activities, machinery, construction vehicles and the potential need for drilling activities, may result in damage to houses, businesses and existing public infrastructures in the urban community. Earth works including trenching for installation of traffic management and signalization systems will be required and is likely to take place within the urban neighborhoods. Open excavations and trenches may pose a community safety concerns, resulting in serious injuries, fatalities or damage to properties and goods from community members, animals and especially children falling into open excavations and trenches, if access is not adequately prevented and managed. As such, an ESMF containing a set of recommendations to prevent, minimize, and control risks to the community from traffic accidents was prepared. The ESMF presents detailed guidance and steps to prepare sub-level project specific ESIAs/ESMP including Contractors’ obligations to prepare and adopt Traffic Management Plan (TMP) as part of the C-ESMP to mitigate and manage construction vehicles and pedestrian interactions while ensuring that adequate design of the proposed Bus Rapid Transit (BRT) infrastructures is consistent with GIIP. During operation, specific traffic measures that include installation and maintenance of all signs, signals, markings, and other devices used to regulate traffic, including posted speed limits, warnings of sharp turns will be designed for the adequate re-routing of the public transportation companies (and private vehicles as well) that currently operate in the corridors of intervention. To that end, the CHSP will include management measures for Public Disclosure assuring the security, health and safety of the BRT users and its complementary facilities users during operation including specific measures for emergency response and preparedness. Such measures will be also developed by the Borrower as part of the ESIAs/ESMPs and presented prior to the start of construction. The Social Assessment highlighted that while 55% respondents found that buses pay attention to disability by allowing them priority in boarding and seating, access to bus infrastructure is not based on universal access. The project will ensure that bus infrastructure is compliant with granting universal access and that contractors include such principles in the construction of bus terminals and other related infrastructure. Lastly, the proposed BRT investments will also have a strong focus on climate change resilience, especially considering flood risk management. Flood adaptation strategies for the BRT will include drainage measures for the network infrastructure aiming to protect the BRT corridor, roads along the BRT corridor, and secondary road network from flooding by ensuring that water runoff is safely discharged. The project will also explore the use nature-based solutions such as upstream flood retention measures. Such measures will not only protect the BRT network but will greatly enhance the flood resilience within project area; while producing an array of co-benefits for the residents including improved aesthetics, ample recreational areas, protection of biodiversity and CO2 sequestration. While in general the project is not expected to rely on outside workers, influx of opportunistic migrants may likely occur, however workers campsite is not unticipated under this projet as labor will be sourced locally. Notwithstanding, there are potential impacts on community health or safety.. In the absence of appropriate mitigation measures, gender-based violence (GBV), sexual exploitation and abuse (SEA), and the spread of sexually transmitted and communicable diseases, may be exacerbated by the presence of a workforce including COVID-19 Apr 14, 2022 Page 14 of 18 The World Bank Maputo Metropolitan Area Urban Mobility Project (P175322) within the community if not carefully managed. The project has therefore prepared a SEA/SH Risk Assessment and Action Plan for Gender Based Violence (GBV) / Sexual Exploitation and Abuse (SEA)/ Sexual Harassment (SH) prior to appraisal, included in the draft ESMF, with the relevant mitigation measures to address these risks. A Communication Plan was developed and attached to the Stakeholder Engagement Plan, that will serve as the instrument to ensure that communities are aware of safety procedures that need to be followed. To avoid or minimize the spread of disease, a COVID-19 protocol was also prepared as part of the ESMF to be disclosed prior to appraisal completion. The design of stations, vehicles and street improvements will conform to the Good Practice Guide on Non- discrimination and Disability under ESS4, which ensure access for persons with disabilities. No security personnel are currently planned to be deployed to the project areas. However, if required, the FCMU will prepare, adopt, and implement a stand-alone Security Personnel Management Plan (SPMP) consistent with the requirements of ESS4, in a manner acceptable to the Bank. Any security personnel engaged by the project will be provided suitable training and sensitization according to national law and GIIP, and codes of conduct shall apply for such personnel. ESS5 Land Acquisition, Restrictions on Land Use and Involuntary Resettlement ESS5 is relevant. BRT related interventions under Component 2 and neighbourhood level investments under Component 3 will require civil works necessitating land acquisition on a permenent and/or temporary basis. A Resettlement Policy Framework (RPF) has been prepared by the project that identifies impacts of land acquisition. Public Disclosure Under Component 1, the extent of land acqusition will depend on final technical design considerations. The RPF, therefore, presents high impact and low impact scenarios. Under high impact, land acquisition for BRT corridor would require permanent land acquisition leading to physical resettlement in an urban context. Low impact scenario would require temporary land use but will not lead to extensive physical resettlement. The RPF also identifies that under the low impact scenario, no new Partial Protection Zone (PPZ) will be created. In case of road widening for BRT, the existing PPZ will be extended and any residents within it will be notified of this status. However, any PAPs facing impacts will be compensated in line with the RPF. Where new infrastructure is created (such as bus depots etc), the need for the creation of a PPZ will be assessed in line with the Land Law. PAPs who face physical or economic impacts will be compensated in line with the RPF while those who continue to live inside the PPZ will be approached to sign user rights agreements to ensure that they are entitled to compensation under the Land Law in case they are moved in future. In line with the RPF, Resettlement Action Plans (RAPs) will be prepared and implemented for each sub-project area. In a dense urban environment, impacts on livelihoods are expected to take place and will need to be carefully assessed especially in relation to small businesses, mobile vendors, informal transport operators and other groups most of whom tend to be poor and marginalized groups. Livelihood impacts on such groups have been assessed in the RPF . These will be screened thoroughly and appropriate instruments will be developed. This can include LRPs either as part of RAPs or standalone ones depending on the nature of the impact. Options for integrating informal livelihoods around the bus network will also be assessed and implemented as part of LRPs. Where there are access restrictions to land use due to civil works, C-ESMPs will include specific mechanisms to manage these through the provision of alternate access. The Project's SEP includes consultation mechanisms including at neighborhood level which will be used to ensure that land acquisition needs and resettlement impacts are clearly communicated and Apr 14, 2022 Page 15 of 18 The World Bank Maputo Metropolitan Area Urban Mobility Project (P175322) discussed with the local residents and users of the areas where civil works will take place. RAPs and LRPs will be developed through technical support contracted for this purpose and implemented through RAP Implementation Service Providers and/or through entities hired for implementation. Staff at PIU levels will oversee the implementation of RAPs and LRPs. During civil works, some impacts may also take place (such as damage to properties). Such impacts will be mitigated through the requirement in C-ESMPs to ensure that land needs are kept to a minimum during construction. Nevertheless, some impacts may require the preparation and implementation of RAPs to address construction related impacts. Such RAPs will be prepared and implemented by Contractors with the Supervision Engineer overseeing their implementation. ESS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources ESS6 is relevant. Since the project will take place in an urban area setting with already humanized environment; there are low to moderate risks to impact natural habitats directly and adversely, as defined under ESS6. Notwithstanding, the medium scale constructions and maintenance works under Components 2 in high densely populated areas and component 3 along the corridors, are likely to include; i) site clearance for construction purposes; ; ii) use borrow pits to source quarry, material laydown area and; iii) earth works consisting of excavations and trenching for transit management and signage systems which may lead to direct and indirect habitat degradation and soil disturbance leading to the introduction of alien and invasive plant species and generate cumulative and indirect impacts as a result of induced land use changes leading to the conversion of natural habitats (wetlands or estuaries) due to potential in-migration. Key Biodiversity Areas (KBA) include the protected mangrove areas of Maputo estuary along Public Disclosure the coastal area of Maputo Bay, the wetland areas along the water courses of Inkomati river in Marracuene, Matola river in Matola City and Infulene river in Maputo city. These ecological sensitive areas located around the proposed the BRT routes. However, since the KBAs are predominantly located in legally protected areas (PAs) areas, they are not likely to be affected by the proposed project interventions. Notwithstanding, the ESMF prepared by the borrower contains provisions for the exclusion of these known areas. The ESMF also includes measures to mitigate direct, indirect, or cumulative impacts on natural habitats in a manner consistent with ESS6. Moreover, project design will explore the use nature-based solutions such as upstream flood retention measures. Such measures will not only protect the BRT network but will greatly enhance the flood resilience within project area; while producing an array of co-benefits for the residents including improved aesthetics, ample recreational areas, protection of biodiversity and natural habitats around the project area. ESS7 Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local Communities ESS7 is not determined as relevant to the project as there are no Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local Communities in Mozambique. ESS8 Cultural Heritage ESS8 is determined as relevant to the project. Cultural property may be impacted if the BRT is to cover the downtown area of Maputo, which has a number of buildings that are considered as Cultural Heritage. For civil works activities under Component 2, the project will seek to preserve heritage buildings and aesthetics of the downtown area. This will imply meticulous planning and implementation of anticipated civil works and ensure that the historical buildings Apr 14, 2022 Page 16 of 18 The World Bank Maputo Metropolitan Area Urban Mobility Project (P175322) maintain their architectural and cultural significance. These buildings will also need to be preserved in line with community aspirations. Any project interventions will address cultural heritage as an integral aspect of Maputo’s Metropolitan Area sustainable urban renewal and development as outlined in the ESMF which includes an assessment of Cultural Resources within the project's footprint and appropriate guidance on including aspects of cultural heritage preservation in designing and engineering works. Proposed investments financed under Component 3 for the corridors expansions include aspects such as site clearing, earth works and excavations for the installation of traffic management systems and signage that could have an impact on tangible and intangible cultural heritage features located within the project footprint and underground. Although the project will not finance activities that will affect cultural heritage resources, “chance find” procedures will be implemented in all construction activities. A Chance Finds Procedure is also outlined in the ESMF and in any subsequent ESIA/ESMP to form part of the contractor’s obligations. ESS9 Financial Intermediaries ESS9 is not determined as relevant to the project as the involvement of Financial intermediaries is not anticipated. B.3 Other Relevant Project Risks There also risks related to BRT infrastructures integrity against natural hazards exposure. Nonetheless, the BRT Public Disclosure structures will conform to the relevant GIIP to prevent, minimize and mitigate climate related events. The risks related to the inclusion of poor, marginalized groups such as women, PWDs, the elderly and children need to be assessed and taken into consideration in the design of transport related interventions and systems. The Project has undertaken a Social Assessment to assess the access to safe, reliable and affordable transport for marginalized groups. It also assesses the issues faced by such groups in using transport and recommend measures to ensure that transport systems and its related infrastructure supported by the Project is informed by a gender and marginalization perspective. T C. Legal Operational Policies that Apply OP 7.50 Projects on International Waterways No OP 7.60 Projects in Disputed Areas No B.3. Reliance on Borrower’s policy, legal and institutional framework, relevant to the Project risks and impacts Is this project being prepared for use of Borrower Framework? No Areas where “Use of Borrower Framework” is being considered: Apr 14, 2022 Page 17 of 18 The World Bank Maputo Metropolitan Area Urban Mobility Project (P175322) With regards to ESF several aspects have not been addressed in standard ESIAs in Mozambique. As such, reliance on the borrower’s E&S framework is not considered to be appropriate. IV. CONTACT POINTS World Bank Contact: Fatima Arroyo Arroyo Title: Senior Urban Transport Specialist Telephone No: 5352+4235 / 1-202-473-5110 Email: farroyoarroyo@worldbank.org Contact: Mohammad Ajmal Askerzoy Title: Senior Transport Specialist Telephone No: 5333+3382 / 93-70-113-3382 Email: maskerzoy@worldbank.org Borrower/Client/Recipient Borrower: Republic of Mozambique Implementing Agency(ies) Implementing Agency: Maputo Metropolitan Transport Agency (AMT) Implementing Agency: Maputo City Council Public Disclosure Implementing Agency: Matola City Council V. FOR MORE INFORMATION CONTACT The World Bank 1818 H Street, NW Washington, D.C. 20433 Telephone: (202) 473-1000 Web: http://www.worldbank.org/projects VI. APPROVAL Task Team Leader(s): Fatima Arroyo Arroyo, Mohammad Ajmal Askerzoy Practice Manager (ENR/Social) David Seth Warren Cleared on 13-Apr-2022 at 12:48:1 GMT-04:00 Safeguards Advisor ESSA Peter Leonard (SAESSA) Concurred on 14-Apr-2022 at 07:22:34 GMT-04:00 Apr 14, 2022 Page 18 of 18