INTEGRATED SAFEGUARDS DATA SHEET RESTRUCTURING STAGE Note: This ISDS will be considered effective only upon approval of the project restructuring Public Disclosure Copy Report No.: ISDSR11743 Date ISDS Prepared/Updated: 14-Jan-2015 Date ISDS Approved/Disclosed: 14-Mar-2014, 14-Jan-2015 I. BASIC INFORMATION 1. Basic Project Data Country: Brazil Project ID: P127723 Project Name: Sao Paulo State Sustainable Transport Project (P127723) Task Team Eric R. Lancelot Leader(s): Estimated 06-Feb-2013 Estimated 14-Jun-2013 Appraisal Date: Board Date: Managing Unit: GTIDR Lending Investment Project Financing Instrument: Sector: Rural and Inter-Urban Roads and Highways (91%), Sub-national government administration (8%), Flood protection (1%) Theme: Infrastructure services for private sector development (46%), Trade facilitation and market access (46%), Natural disaster managemen t (4%), Environmental policies and institutions (3%), Land administration and management (1%) Is this project processed under OP 8.50 (Emergency Recovery) or OP 8.00 (Rapid Response to Crises and Public Disclosure Copy No Emergencies)? Financing (in USD Million) Total Project Cost: 729.00 Total Bank Financing: 300.00 Financing Gap: 0.00 Financing Source Amount Borrower 129.00 International Bank for Reconstruction and Development 300.00 MIGA Guarantee 300.00 Total 729.00 Environmental B - Partial Assessment Category: Is this a No Repeater project? 2. Current Project Development Objectives Page 1 of 10 The Project Development Objective is to contribute to improving the State’s transport efficiency and safety while enhancing the Borrower’s capacity in environmental and disaster risk management. Public Disclosure Copy The objective is to be achieved through (a) upgrading selected key transport corridors including their rehabilitation and expansion, and mainstreaming transport planning and management, (b) capacity building in land use planning and territorial management and regulation focusing on addressing environmental impacts in support of a greener and more inclusive growth, and (c) improvement of the State’s capacity to manage disaster risk, particularly risks linked to climate change in the transport sector in SoSP. Proposed New PDO (from Restructuring Paper) The Project Development Objective is to contribute to improving the State’s transport efficiency and safety while enhancing the Borrower’s capacity in environmental and disaster risk management. The objective is to be achieved through (a) upgrading selected key transport corridors including their rehabilitation and expansion, and mainstreaming transport planning and management, (b) capacity building in land use planning and territorial management and regulation focusing on addressing environmental impacts in support of a greener and more inclusive growth, and (c) improvement of the State’s capacity to manage disaster risk, particularly risks linked to climate change in the transport sector in SoSP. 3. Project Description The Project will be a US$729 million operation financed by a US$300 million Bank loan, US$129 million of counterpart funds and a US$300 million joint-financing from private banks covered by MIGA’s NHSFO guarantee. The Project includes the following three components as described below. Component 1: Improving transport and logistics efficiency and safety (Estimated cost US$694.25 million of which US$275.45 million will be financed by the Bank Loan and US$300 million by Public Disclosure Copy private bank(s) covered by MIGA NHSFO and US$118.8 million by counterpart financing) Provision of support to improve the State transport and logistics efficiency and safety, through the carrying out of the following activities: 1.1 Rehabilitating and upgrading the Borrower’s transport networks (US$686.5 million, of which US$269.5 to be financed by the Bank and US$300 by the private commercial bank Santander which could be covered by MIGA’s NHSFO guarantee), in support to the Road Agency (DER) road rehabilitation and upgrading program. Restore and upgrade the State’s transport networks to improve connectivity, reduce logistics costs and improve road transport safety through the rehabilitation and improvement of the existing transport infrastructures. Interventions will include, inter alia: (a) road rehabilitation, construction of third lanes, duplications, slope protection and improvement of intersections on a total of approximately 650 km of existing selected paved State roads identified for their potential contribution to intermodality, (b) the reconstruction of two bridges with wider clearance on the rivers Tietê and Piracicaba to enhance waterway navigability of these rivers, (c) a pilot of Performance Based Contracts (PBC) for rehabilitation and road maintenance on about 100 km (see box 4 in annex 2 of the PAD on Brazil experience on PBC), (d) improving road safety through pilot works based on the recommendations of World Bank GRSF Trust Fund financed iRAP pilot survey (see box 3 in annex 2 of the PAD on iRAP). 1.2 Sustainable transport planning and management (US$8.5 million, of which US$5.95 million financed by the Bank). Improvement of the State capacity to plan and manage the sector through studies and the acquisition of goods to the benefit of the Secretariat of Logistics and Transport’s Page 2 of 10 (SLT) aimed at, inter alia (i) improving transport planning and management with a view to increase multimodality, while embedding disaster risk management as an instrument of public policy, in support to the State land use planning and territorial management agenda, (ii) greening transport in Public Disclosure Copy the State through pilots notably based on the recommendations of the World Bank “Green Freight” study, (iii) enhancing transport impact assessment understanding, (iv) improving road safety based on the recommendations of the World Bank GRSF financed capacity assessment in road safety. Component 2: Strengthening sustainable environmental and land use planning and territorial management capacity (Estimated cost of US$18 million, of which US$12.6 million financed by the Bank Loan and US$5.4 million by counterpart financing) Provision of support in the area of land use planning and territorial management and environmental management, through the carrying out of following activities: 2.1 Supporting sustainable land use planning and territorial management (US$5 million of which US$3.5 million financed by the Bank). Improvement of the State capacity to plan and manage sustainable land use and territorial development in an integrated fashion through studies and the acquisition of goods aimed at, inter alia: (i) supporting the Planning and Regional Development Secretariat (SPDR) in the establishment of an integrated land use planning and territorial management for the SoSP, with an aim at articulating sector planning and management policies in transport, environment and disaster risk management, and (ii) supporting the State Secretariat of Environment (SMA) in the implementation of the Economic and Ecological Zoning (EEZ) with an aim at providing objective orientation for public investments and development strategies; 2.2 Improving environmental enforcement and environment quality monitoring (US$6.5 million of which US$4.55 million financed by the Bank). Improvement of the State capacity to manage and monitor environment through studies, small works and the acquisition of goods aimed at, inter alia: (i) improving environmental monitoring and control of the SMA with a view to strengthen enforcement, through pilot initiatives focusing on innovation including the acquisition of equipment on a pilot basis, and (ii) strengthening the capacity of the State Environmental Agency (CETESB) in air and water monitoring in the Project area to ensure efficient and reliable data collections on air and water quality; Public Disclosure Copy 2.3 Supporting the modernization of the Environmental Licensing System (US$6.5 million of which US$4.55 million financed by the Bank). Improvement of the State capacity to efficiently process environmental licenses and environmental strategic assessment services through studies and the acquisition of goods to the benefit of the CETESB aimed at, inter alia: (i) strengthening the understanding of environmental impacts of public and private investments and activities, (ii) upgrading and updating the management systems for processing environmental licenses and simulating potential environmental impacts, and (iii) enhancing the capacity of the CETESB. Component 3: Increasing State’s resilience to natural disasters (Estimated cost US$16 million of which US$11.2 million financed by the Bank Loan and US$4.8 million by counterpart financing) Provision of support to enhance the State capacity to plan for and manage disasters through the carrying out the following activities: 3.1 Mainstreaming disaster risk management in the transport sector (US$5.5 million of which US $3.85 financed by the Bank Loan). Improvement of the State capacity to mainstream disaster risk management in transport planning and work execution through studies, small works and the acquisition of goods to the benefit of the Geologic Institute (IG) aimed at, inter alia: (i) mainstreaming disaster and climate change risk in the Borrower’s transport masterplan (PDLT), including assessing sector vulnerability to natural disasters, notably resulting from climate events and potential socio economic impacts, and developing an integrated disaster response plan for the transport sector; and (ii) reviewing technical specifications for road design and maintenance to Page 3 of 10 improve resiliency of road infrastructure exposed to mapped risks. 3.2 Enhancing disaster risk management policy and institutional capacity (US$10.5 million of which US$7.35 financed by the Bank Loan). Strengthening the State capacity for disaster risk management Public Disclosure Copy through studies and the acquisition of goods to upgrade and support the implementation of the State’s disaster risk management program (Programa Estadual de Prevenção de Desastres Naturais e de Redução de Riscos Geológicos - PDN) to the benefit of the IG, including inter alia: (i) mainstreaming disaster risk management practices at planning level, through supporting the design of disaster risk management frameworks, improving comprehensive conceptual and practical understanding of hazards, vulnerabilities and risks, assessing economic and social impacts of particular disasters, and designing management tools for the resettlement of populations located in immitigable high-risk areas; and (ii) improving policies and procedures to better and more effectively respond to disasters, through the development of early warning systems, methodologies and sharing of information and knowledge. 4. Project location and salient physical characteristics relevant to the safeguard analysis (if known) For Component 1 – Transport: the Project will finance the rehabilitation and upgrade of a set of State paved roads and the reconstruction of two bridges in the State of Sao Paulo. The planned road works are located in the central and northwest regions of the State, and will mostly take place within the rights of way (ROW) and in sites associated with the road projects. The ROW consists of the paved strip and the entire area reserved for the construction, operation, and maintenance of the roadside. The sites associated with road projects include deposits; borrow sites, materials treatment areas, quarries, access roads, and facilities provided for project workers. The bridges will be reconstructed in the same locations as the existing bridges, and depending on the construction technology chosen, it will be possible to maintain use of the existing bridge during the construction period. Bridges will be on SP-191, which crosses over the Piracicaba River and the other is on the SP-147 over the Tietê River. Given the fact that no new road will be constructed and most of areas along the planned roads have been developed as farms, it is not expected that the civil works would have negative impacts on existing environmentally protected areas or indigenous people. These interventions will also be Public Disclosure Copy located within an area where there are isolated patches of natural vegetation and land use is predominantly focused on agriculture (ex: sugar cane, soya bean, oranges, cattle ranching, etc.). For Component 2 and Component 3 – Environment and Disaster Risk Management: Particular activities may be relevant for specific geographical areas, such as regarding forest conservation in pilot areas or action plans for resettlement of those in risk prone areas, near the coastal regions. Salient physical characteristics During implementation, the Project is not expected to cause any large scale, significant and/or irreversible negative environmental impacts. As it supports a number of site specific investments in, or near existing road infrastructure, the incremental environmental impacts resulting from construction works will be limited in spatial extent and time, mainly during the execution of civil works. Likewise, the environmental impact of the reconstruction of two bridges in replacement of existing ones should be limited to the site of intervention with limited consequences on environment. While most direct negative impacts on environment from the Project are expected to be limited in time and localized near the civil works sites, other impacts, with potential positive effect on the environment, will result from the improvements on territorial planning, environmental monitoring and environmental licensing process. The expected enhancement on these activities has direct effects on biodiversity protection, sustainable land use management, forests and other natural habitats conservation and sustainable hydrological resources management. Also, increasing State’s resilience Page 4 of 10 to natural disasters brings benefits to the environment, for example through reorganization and planning of land use, contributing to the preservation of sensitive areas, especially in the urban environment of municipalities located in risk prone areas. Public Disclosure Copy 5. Environmental and Social Safeguards Specialists Jason Jacques Paiement (GSURR) Marcio Cerqueira Batitucci (GENDR) 6. Safeguard Policies Triggered? Explanation (Optional) Environmental Assessment Yes OP/BP 4.01 Natural Habitats OP/BP Yes 4.04 Forests OP/BP 4.36 Yes Pest Management OP 4.09 Yes Physical Cultural Resources Yes OP/BP 4.11 Indigenous Peoples OP/BP Yes 4.10 Involuntary Resettlement Yes OP/BP 4.12 Safety of Dams OP/BP 4.37 No Projects on International No Waterways OP/BP 7.50 Projects in Disputed Areas No OP/BP 7.60 Public Disclosure Copy II. Key Safeguard Policy Issues and Their Management A. Summary of Key Safeguard Issues 1. Describe any safeguard issues and impacts associated with the Restructured project. Identify and describe any potential large scale, significant and/or irreversible impacts: During implementation, the Project is not expected to cause any large scale, significant and/or irreversible negative environmental impacts. As it supports a number of site specific investments in, or near existing road infrastructure, the environmental impacts resulting from construction work are expected to be limited in spatial extend and time, mainly during the execution of civil works. Likewise, the environmental impact of the reconstruction of two bridges in replacement of existing ones (all of which have already been visited by the team), should be restricted to the site of intervention with limited consequences on the environment. The most commonly expected negative impacts would arise from the construction phase under Component 1, which includes work interventions mostly within rights of way of existing roads, although these impacts are expected to be small, transitory and of short duration. In this sense, the social and environmental risks associated with this Project are limited due to the nature of the proposed interventions, which will mostly take place within the existing rights-of-way of the road and in sites associated with road projects (in very limited cases, for example, duplication works at Page 5 of 10 an intersection may require a small land beyond of the existing rights-of-ways to ensure safe road alignment). Public Disclosure Copy While most direct negative environmental impacts from the Project are expected to be limited in time and localized near the civil works sites, other impacts, with potential positive effect on the environment, will result from the improvements on territorial planning, environmental monitoring and environmental licensing process. The expected enhancement on these activities has direct effects on biodiversity protection, sustainable land use management, forests and other natural habitats conservation and sustainable hydrological resources management. Also, increasing State’s resilience to natural disasters brings benefits to the environment, for example through land use reorganization and planning, contributing to the preservation of sensitive areas, especially in the urban environment of municipalities located in risk prone areas. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area: Rehabilitation and upgrading of the Borrower’s transport networks is expected to generate significant positive social impacts. In addition to reduced transportation costs and increased accessibility to markets and public services, the Project is expected to improve road safety conditions, generate positive impacts on land values, create jobs, and raise incomes throughout the state. By improving the efficiency of the State’s logistics, the Project is expected to strengthen agriculture industry in the State and beyond, which in turn, might increase pressure to convert the native environment for commercial use. Those potential impacts, assessed in detail in the ESIA and the complementary assessment (Environmental and Social Impact Assessment - ESIA- Complementary dated January 2014 which complements the original ESIA report on January 2013), are however expected to be limited because: (i) most of the native vegetation in the State of Sao Paulo has already been modified and the State has a strong regulation and enforcement capacity, which will be further strengthened under the Project second component, (ii) in the central west region of the SoSP, where agricultural activities are more intense and where the interventions of Project component 1 are also planned, the native vegetation fragments are often associated with Public Disclosure Copy water courses, critical to these activities, (iii) investments in research and technology ensure higher productivity without necessarily expanding acreage, (iv) existing SoSP experiments show the importance of preserving fragments of native vegetation to the health of monoculture crops like sugar cane and (v) immediate neighboring States (some of which the Bank work with, including in strengthening environment monitoring capacity, such as the State of Mato Grosso do Sul) and beyond, the Federal Government, also dispose of a contingent of laws and regulations as well as enforcement capacity to mitigate such impacts. These positive impacts are expected to be further enhanced through the complementary interventions proposed for Components 2 and 3. Activities under component 2 are expected to have a positive impact on the environment, since the component seeks to promote environmental compliance, planning and monitoring. It will support the SoSP’s efforts to strengthen environmental management tools aimed at sustainable land use and reduce negative environmental impacts. The Territorial planning and management will focus on promoting sustainable land use at the State level. Activities under this subcomponent should lead to positive impacts on natural habitats, through the identification of critical natural areas. In the preparation of the EEZ, multiple consultations will be organized by the Borrower with regional committees in order to identify the priorities and actions required to reach the expected results. At the same time, the Borrower will implement an on-line public accounts system to facilitate public oversight of government actions. Enforcement activities under the Project component could also lead to changes in the exploitation Page 6 of 10 patterns of natural resources either by private companies and/or individual and communities. From Component 3, the proposed activities also bring benefits to the environment in a sensitive context, especially in the urban environment. Public Disclosure Copy 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. The project includes road improvement and rehabilitation on existing roads prioritized by the State program. The alternatives would be different road segments but this would not change the nature or scale of impacts significantly. 4. Describe measures taken by the borrower to address safeguard policy issues. Provide an assessment of borrower capacity to plan and implement the measures described. The State of Sao Paulo Road Agency (DER-SP) has considerable experience with World Bank safeguard policies through implementation of two previous projects: State Highways Management Project Sao Paulo (P006410-closed) and the Sao Paulo Feeder Roads & Additional Financing (P106663-active) as well as an IADB Sao Paulo State Highway Rehabilitation Project (BR- L1033). The ongoing World Bank project is focused on municipal road rehabilitation and includes technical assistance for modernizing the State’s environmental management systems. The implementation of the proposed Project would be undertaken through the same agency (DER- SP.) which will be in charge of supervising all safeguards aspects for all components, including for the other beneficiaries/participating entities. The DER-SP will centralize, coordinate and monitor all Project activities, including the environmental and disaster risk management components. A consulting company will support the environmental and social impact management capacity of the DER-SP, and each participating entity will regularly report safeguard related information to DER- SP. The technical responsibility for preparation, supervision, monitoring and evaluation of project outcomes and results will be shared between the different beneficiary agencies, in their respective areas of responsibility, under the supervision of the UCPR within the DER. The UCPR/DER-SP Public Disclosure Copy will be responsible for final reporting to the Bank in terms of quality, timing etc. The diverse project coordinators at each of the secretariats will be responsible for reporting to the UCPR information on, among others, procurement planning, preparation of technical specifications and terms of reference for procurement documents, bills, safeguards planning, implementation and monitoring, among others. The borrower has demonstrated adequate capacity and procedures to deal with environmental mitigation measures. Environmental management of the works under the Project will be overseen by independent consulting firms, following the best practices inherited from other transportation projects in Sao Paulo and Brazil. The Bank Team found under a recent Project with similar works that the supervision performance of the borrower has been satisfactory. The borrower is responsible for all costs related to the design, implementation, monitoring and evaluation of these safeguard policy measures. These costs (additional staff at the UCPR, independent environmental supervision, etc.) are included in the DER’s operational budget. 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. Among many potentially interested stakeholders of the Project are transport operators and users, agribusiness and environmental resource managers, and private land owners and residents of areas identified as vulnerable to natural disasters. Project details and the results of the Environmental Page 7 of 10 and Social Impact Assessment (ESIA) are posted on the Borrower’s website and were also discussed during public consultations at the DER-SP office in Sao Paulo on December 12, 2012. The complement to the ESIA specific to the road sections added to the Project was disclosed by Public Disclosure Copy the borrower on January 23, 2014 and submitted to InfoShop (03/14/2014. More than 70 government agencies, private sector groups and civil society organizations were invited to review the ESIA and provide comments. Additional consultations were held with FUNAI – Brazil’s National Indian Foundation – to assess the appropriateness of the Indigenous Peoples Planning Framework (IPPF). Key recommendations regarding institutional responsibilities, access to project products and benefits, and road safety issues were received and integrated into the project design and impact management plans. The additional project activities assessed through the complement to the ESIA are similar in scope and nature to those previously assessed for which the consultation held during the original ESIA. The proposed civil works on the additional road sections do not trigger any additional safeguards, and the client has demonstrated satisfactory capacity using existing environmental and social frameworks to identify and manage probable impacts and risks. These procedures are strengthened by independent environmental supervision of construction activities and a well publicized toll-free information service. B. Disclosure Requirements Environmental Assessment/Audit/Management Plan/Other Was the document disclosed prior to appraisal? Date of receipt by the Bank 22-Jan-2013 Date of submission to InfoShop 23-Jan-2013 For category A projects, date of distributing the Executive Summary of the EA to the Executive Directors "In country" Disclosure Brazil 29-Jan-2013 Comments: Public Disclosure Copy Resettlement Action Plan/Framework/Policy Process Was the document disclosed prior to appraisal? Date of receipt by the Bank 22-Jan-2013 Date of submission to InfoShop 23-Jan-2013 "In country" Disclosure Brazil 29-Jan-2013 Comments: Indigenous Peoples Development Plan/Framework Was the document disclosed prior to appraisal? Date of receipt by the Bank 22-Jan-2013 Date of submission to InfoShop 23-Jan-2013 "In country" Disclosure Brazil 29-Jan-2013 Comments: Pest Management Plan Was the document disclosed prior to appraisal? Yes Page 8 of 10 Date of receipt by the Bank 22-Jan-2013 Date of submission to InfoShop 23-Mar-2013 "In country" Disclosure Public Disclosure Copy Brazil 23-Jan-2014 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 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 OP/BP/GP 4.01 - Environment Assessment Does the project require a stand-alone EA (including EMP) Yes [ ] No [ ] 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 incorporated Yes [ ] No [ ] NA [ ] in the credit/loan? OP/BP 4.04 - Natural Habitats Would the project result in any significant conversion or Yes [ ] No [ ] NA [ ] degradation of critical natural habitats? If the project would result in significant conversion or Yes [ ] No [ ] NA [ ] degradation of other (non-critical) natural habitats, does the Public Disclosure Copy project include mitigation measures acceptable to the Bank? OP 4.09 - Pest Management Does the EA adequately address the pest management issues? Yes [ ] No [ ] NA [ ] Is a separate PMP required? Yes [ ] No [ ] NA [ ] If yes, has the PMP been reviewed and approved by a Yes [ ] No [ ] NA [ ] safeguards specialist or PM? Are PMP requirements included in project design?If yes, does the project team include a Pest Management Specialist? OP/BP 4.11 - Physical Cultural Resources Does the EA include adequate measures related to cultural Yes [ ] No [ ] NA [ ] property? Does the credit/loan incorporate mechanisms to mitigate the Yes [ ] No [ ] NA [ ] potential adverse impacts on cultural property? OP/BP 4.10 - Indigenous Peoples Has a separate Indigenous Peoples Plan/Planning Framework Yes [ ] No [ ] NA [ ] (as appropriate) been prepared in consultation with affected Indigenous Peoples? Page 9 of 10 If yes, then did the Regional unit responsible for safeguards or Yes [ ] No [ ] NA [ ] Practice Manager review the plan? If the whole project is designed to benefit IP, has the design Yes [ ] No [ ] NA [ ] Public Disclosure Copy been reviewed and approved by the Regional Social Development Unit or Practice Manager? OP/BP 4.12 - Involuntary Resettlement Has a resettlement plan/abbreviated plan/policy framework/ Yes [ ] No [ ] NA [ ] process framework (as appropriate) been prepared? If yes, then did the Regional unit responsible for safeguards or Yes [ ] No [ ] NA [ ] Practice Manager review the plan? OP/BP 4.36 - Forests Has the sector-wide analysis of policy and institutional issues Yes [ ] No [ ] NA [ ] and constraints been carried out? Does the project design include satisfactory measures to Yes [ ] No [ ] NA [ ] overcome these constraints? Does the project finance commercial harvesting, and if so, Yes [ ] No [ ] NA [ ] does it include provisions for certification system? The World Bank Policy on Disclosure of Information Have relevant safeguard policies documents been sent to the Yes [ ] No [ ] NA [ ] World Bank's Infoshop? Have relevant documents been disclosed in-country in a public Yes [ ] No [ ] NA [ ] place in a form and language that are understandable and accessible to project-affected groups and local NGOs? All Safeguard Policies Have satisfactory calendar, budget and clear institutional Yes [ ] No [ ] NA [ ] Public Disclosure Copy responsibilities been prepared for the implementation of measures related to safeguard policies? Have costs related to safeguard policy measures been included Yes [ ] No [ ] NA [ ] in the project cost? Does the Monitoring and Evaluation system of the project Yes [ ] No [ ] NA [ ] include the monitoring of safeguard impacts and measures related to safeguard policies? Have satisfactory implementation arrangements been agreed Yes [ ] No [ ] NA [ ] with the borrower and the same been adequately reflected in the project legal documents? III. APPROVALS Task Team Leader(s): Eric R. Lancelot Approved By Regional Safeguards Name: Date: Coordinator: Sector Manager: Name: Aurelio Menendez (SM) Date: 14-Jan-2015 Page 10 of 10 The original had problem with text extraction. pdftotext Unable to extract text.