Page 1 INTEGRATED SAFEGUARDS DATASHEET APPRAISAL STAGE I. Basic Information Date prepared/updated: 02/18/2010 Report No.: AC5053 1. Basic Project Data Country: Ghana Project ID: P115247 Project Name: Ghana---Social Opportunities Project Task Team Leader: Qaiser M. Khan Estimated Appraisal Date: February 22, 2010 Estimated Board Date: May 27, 2010 Managing Unit: AFTSP Lending Instrument: Specific Investment Loan Sector: Other social services (90%);Public administration- Other social services (5%);Public administration- Agriculture, fishing and forestry (5%) Theme: Social safety nets (70%);Social risk mitigation (15%);Rural services and infrastructure (7%);Rural non-farm income generation (5%);Natural disaster management (3%) IBRD Amount (US$m.): 0.00 IDA Amount (US$m.): 89.00 GEF Amount (US$m.): 0.00 PCF Amount (US$m.): 0.00 Other financing amounts by source: BORROWER/RECIPIENT 2.40 Financing Gap 0.30 2.70 Environmental Category: B - Partial Assessment Simplified Processing Simple [X] Repeater [] Is this project processed under OP 8.50 (Emergency Recovery) or OP 8.00 (Rapid Response to Crises and Emergencies) Yes [ ] No [X] 2. Project Objectives 1. The proposed Project Development Objectives (PDO) of the Social Opportunities Project (SOP) are to improve targeting in social protection spending, increase access to conditional cash transfers nationwide, increase access to employment and cash-earning opportunities for the rural poor during the agricultural off-season, and improve economic infrastructure in target districts. 2. The project will increase opportunities for the poor to help themselves by: (i) financing public works using labor intensive construction methods that create employment, with priority given to the poorest districts of the country, predominately located in the three northern regions; (ii) providing incremental support to scale up the conditional cash transfer program (LEAP), whereby the poorest households are paid to participate in education and health services; (iii) improving links between disaster response planning and the utilization of social safety nets; and (iv) developing the government#s capacity to implement safety net programs both at the central level and Page 2 through decentralized structures (i.e., primarily District Assemblies). In addition, the rehabilitation and/or development of small-scale productive infrastructure in target districts are/is expected to create secondary employment and income-generation effects 3. A prudent targeting strategy is the single-most critical element for successful implementation of the project, in particular for the LIPWs. The project will use a combination of geographical and household selection. In view of the fact that geographic targeting will result in selection of the poorest districts (i.e., those with poverty incidence as high as 80 percent), the approach to targeting households for the public works program is to ensure a fair distribution of opportunities between all those who can work and wish to take part. Extensive consultations carried out during project preparation confirmed a strong preference for the community itself to be involved in overseeing the distribution of opportunities for work. The communities placed a high value on transparency and involving community institutions in assuring accountability. Ensuring gender equity will be a basic principle. 4. The will be implemented over a five year period and includes five components: (i) rationalizing the National Social Protection Strategy; (ii) labor intensive public works (LIPW); (iii) supporting the Livelihood Empowerment Against Poverty Program (LEAP); (iv) building capacity at the central and district levels to plan and implement LIPW and LEAP and to strengthen the decentralization process and national disaster risk management programs; and (v) project management and coordination. 5. The total cost of the proposed project is US$90 million. The project would be financed through a Sector Investment Loan comprising an IDA Credit of US$87.4 million equivalent including ordinary IDA resources of US$40 million and special Crisis Response Window resources of US$47.4 million. The GOG contribution would be equivalent to US$2.6 million. Should additional funds be available from interested co- financiers, the number of districts covered by labor intensive public works (LIPW) can be increased using the poverty ranking of the different districts as the criteria of selection. Each new district added to the LIPW will cost approximately US$2.5 million. 6. Details on project components are provided below. Component One: Rationalize National Social Protection Policy. (US$3 million, including an IDA contribution of US$3 million) 7. This component will support to the government to help redirect its social protection expenditures to the most effective areas and reduce those in less effective activities. This would allow greater coverage of the poor despite current fiscal constraints. To facilitate the process, the component would finance technical assistance, studies, training, and Secretariat services. This would require the cooperation of many ministries and it would be best to give the lead to a non-sectoral ministry without any programs of its own in social protection but which would have the necessary interest and clout to lead and include all involved ministries. The best candidate for this would be the Ministry of Finance and Economic Planning (MFEP) with implementation services being provided by the project management and coordination team in Ministry of Local Government and Rural Development (MLGRD). Component Two: Labor Intensive Public Works (LIPW). (US$54.4 million, including an IDA contribution of US$54.4 million) Page 3 8. The objective of this component is to provide targeted rural poor households with access to employment and income-earning opportunities. This pertains particularly to seasonal labor demand shortfalls that is, the agricultural off-season from November to March/April, and in response to external shocks, through rehabilitation and maintenance of public or community infrastructure. The aim is to maximize local employment while rehabilitating productive infrastructure assets, which have potential to: (i) generate local secondary employment effects and (ii) protect households and communities against external shocks. The component will establish a LIPW-based social protection scalable instrument that provides quick-response mechanisms against external shocks, such as floods or droughts, during a crisis. The payment modality for LIPWs will be cash. The scope of works eligible for LIPWs will be defined based on labor content and scope to generate significant local employment. 9. The poor state of infrastructure remains a major obstacle to economic development in rural areas, especially in the northern regions. For example, it has been estimated that about 60 percent of the 11,800km of rural roads and a majority of over 900 small (earth) dams and dugouts in the three northern regions are in poor to fair condition. It is expected that LIPWs will target assets that are both highly appreciated by communities and allow for timing of labor inputs during the dry season: a. Rehabilitation and maintenance of rural feeder and access roads: Although the #utility# value of access roads was not rated as highly as dams, the fact that the labor opportunities made available are sufficient to allow for people to plan a dry season #at home# is highly appreciated, as well as the possibility of earning sufficient cash to strengthen the base of household livelihoods. b. Rehabilitation of small dams and related public infrastructure: Where dams allow for dry season irrigated agriculture, it has a dramatic impact on local livelihoods, greatly reducing the incentive to migrate away from the region during the dry season. c. Dugouts are of great significance in much of the northern region, where underground water sources are insufficient to provide for domestic and livestock needs through the dry season. 10. The LIPWs will be selected from the Medium-Term District Development Plans (MTDDPs) and/or related Area Council Action Plans (ACAPs) based on a set of criteria to: (i) maximize rural employment (high labor content); (ii) create or rehabilitate public or collective (i.e., community) assets; (iii) create or rehabilitate productive assets capable of generating secondary employment and economic development within local communities; (iv) undertake LIPWs within reasonable proximity of target populations; (v) avoid competing with labor demand from the agricultural sector (i.e., appropriate timing); (vi) comply with social and environmental safeguards; and (vii) ensure equal opportunity for women and men to participate. However, it will be necessary to review the MTDDPs and ACAPs in the selected project districts at the start of the project to update them and ensure that the respective project activities would be fully integrated with other ongoing feeder road and small dam rehabilitation activities that may be financed by other sources. 11. In line with government#s ongoing decentralization process, the labor intensive public works will be implemented through District Assemblies and by relevant line agencies like the Department of Feeder Roads, the Government Irrigation Development Page 4 Agency, the Department of Social Welfare, and the National Disaster Management Organization. Component Three: Livelihood Empowerment Against Poverty Program (LEAP). (US$20 million, including an IDA contribution of US$20 million) 12. The objective of this component is to support the full rollout of the pilot phase of the LEAP program by strengthening its management and administration, improving targeting, and providing incentives to ensure that GOG's annual budget allocations are sufficient. 13. There is recognition within the government and among the partners of the need to build additional capacity within the LEAP administration at the national, regional, district, and community levels to (i) allow for the rapid expansion of the program and (ii) adjust the program to better target the neediest. To this extent, an operational review of LEAP early in 2010 will prepare an Action Plan. DFID, USAID, and UNICEF are expected to support this action plan in the fields of capacity building to improve performance and effectiveness of the implementing agencies, as well as strengthening accountability. The project would also contribute in the form of additional complementary support by providing equipment, training, monitoring and evaluation support, and any additional technical support necessary to improve management, targeting, and the use of Information and Communication Tools (ICTs). Furthermore, the project will specifically aim to improve targeting of LEAP and its self-help aspect by supporting stronger enforcement of human development requirements#especially for households with children of school age. SOP will take the long view of building a nimble and flexible LEAP operation in order to meet national emergencies such as food shortages and famine. 14. In addition, the project will finance incentive payments to the unified treasury account to assure that GOG each year allocates sufficient budget for LEAP to meet its target of 164,370 households by 2012, and will thereby contribute to the improved human capital outcomes for these households. This will be done through conditional Disbursement-Linked Incentives (DLI), which will include: (i) success in reaching the target households as evidenced by actual expenditures and (ii) progress on implementing the Action Plan for LEAP. To ensure that these expenditures are mainstreamed into the GOG budget, the IDA-DLI payments will not exceed one-third of the actual budget expenditures in any given year of the LEAP program. Component Four: Capacity Building. (US$5.4 million, including an IDA contribution of US$5.4 million) 15. The objective of this component is to create capacity at the national and local levels to implement the National Social Protection Strategy (NSPS) in selected project districts, with the view of enabling a gradual scaling-up and targeting at the national level. This component will therefore implicitly strengthen GOG#s decentralization program. Five distinct sets of capacity-building activities will be supported. 16. Establishing a LIPW-supportive policy and institutional framework (US$260,000). The project will support GOG to amend and adapt the existing policy and regulatory framework to stimulate a wider use of labor-based methods, both as social protection and infrastructure-generation mechanisms. The following specific activities will be undertaken: (i) a detailed review of the current policy and regulatory framework as it relates to labor-based methods; (ii) national consultations with all relevant Page 5 stakeholders; (iii) drafting of a new framework and a new bill on labor-based methods, to be presented to Parliament for approval; and (iv) an information and sensitization campaign, at the national and regional levels, for decision-makers, concerned private operators, and the population at-large. 17. Capacity building to support LIPW implementation (US$1,410,000) is aimed at decision-makers, DA technical staff, relevant line agencies, and private contractors and follows the below breakdown: # Rehabilitation and maintenance of roads (US$1,410,000): The project will support the re-establishment of the training program for contractors and relevant district and regional road engineers by the Koforidua Training Center, which was recently renovated, and the terms of reference for course designs have already been prepared by the International Labor Organization (ILO); and # Rehabilitation of small dams and water storage infrastructure (US$100,000): The project will support limited dam and irrigation design and construction training to complement that being planned for 2010 under the IFAD-AfDB#funded Northern Rural Growth Project (NRGP). 18. Capacity building to support implementation of LEAP (US$500,000) to complement ongoing technical support financed by DFID and UNICEF/USAID as needed, with the objective of strengthening and improving the targeting and monitoring of the government#s social protection instruments and programs (e.g., LEAP). The project will also support the capacity of the central unit of the Ministry of Employment and Social Welfare to plan, develop, and monitor social protection and District Assemblies to implement the programs. 19. Capacity building for disaster risk management (US$2,350,000). There is a close link between disaster response planning and the utilization of social safety nets to effectively respond to the needs of those who are affected. The project will therefore support a series of inter-related capacity-building activities in the three northern regions and in proposed project districts: (i) strengthening national risk management strategies and institutions; (ii) capacity building for risk and vulnerability assessment, early warning, and contingency planning at the district level; (iii) public awareness raising at the district and community levels; and (iv) strengthening of emergency preparedness and response at the local and community levels. The activities supported by the project would be part of the overall national program of the Global Facility for Disaster Reduction and Recovery (GFDRR) and would be integrated in its medium-term and annual work plans. 20. District and regional capacity building (US$750,000) to strengthen the technical and management capacities of the three Regional Coordinating Committees (RCCs), ten to fifteen District Assemblies (DAs), and at least two Area Councils (ACs) in each of the selected districts to: (i) identify, prioritize, and plan their development needs#in particular in terms of rural infrastructure and disaster risk management; and (ii) strengthen fiduciary capacities (i.e., financial management, procurement, and monitoring and evaluation). Capacity-building support will be implemented through on-the-job-training and specific short training courses tailored to the needs of RCCs and DAs. Component Five: Project Management and Coordination. (US$6 million, including an IDA contribution of US$5.8 million) 21. The institutions, structures, and capacities of the Government of Ghana will serve as the foundation for project management and coordination. With the aim of bolstering Page 6 GOG operations, the Social Opportunities Project will fund costs associated with: project management and coordination; relevant technical assistance; project monitoring and evaluation; consultancy services; communication and training; equipment and vehicles; and incremental operating costs. In addition, the component will include the cost of annual impact evaluation surveys, including a baseline study and an end-of-the-project comprehensive impact evaluation study (US$1 million). 3. Project Description The proposed project of a five year implementation period has five components: (i) rationalizing the National Social Protection Strategy; (ii) labor intensive public works (LIPW); (iii) supporting the Livelihood Empowerment Against Poverty Program (LEAP); (iv) building capacity at the central and district levels to plan and implement LIPW and LEAP and to strengthen the decentralization process and national disaster risk management programs; and (v) project management and coordination. The total cost of the proposed project is US$90 million. The project would be financed through a Sector Investment Loan comprising an IDA Credit of US$87.4 million equivalent including ordinary IDA resources of US$40 million and special Crisis Response Window resources of US$47.4 million. The GOG contribution would be equivalent to US$2.6 million. Should additional funds be available from interested co- financiers, the number of districts covered by labor intensive public works (LIPW) can be increased using the poverty ranking of the different districts as the criteria of selection. Each new district added to the LIPW will cost approximately US$2.5 million. Details on project components are provided below. Component One: Rationalize National Social Protection Policy. (US$3 million, including an IDA contribution of US$3 million) This component would provide support to the government to help redirect its social protection expenditures to the most effective areas and reduce those in less effective activities. This would allow greater coverage of the poor despite current fiscal constraints. To facilitate the process, the component would finance technical assistance, studies, training, and Secretariat services to facilitate the process. This would require the cooperation of many Ministries and it would be best to give the lead to a non-sectoral ministry without any programs of its own in social protection but which would have the necessary interest and clout to lead but including all involved ministries. The best candidate for this would be the Ministry of Finance and Economic Planning (MFEP) with implementation services being provided by the project management and coordination team in Ministry of Local Government and Rural Development (MLGRD). Component Two: Labor Intensive Public Works (LIPW). (US$47 million, including an IDA contribution of US$45 million) The objective of this component is to provide targeted rural poor households with access to employment and income-earning opportunities. This pertains particularly to seasonal labor demand shortfalls that is, the agricultural off-season from November to March/April. and in response to external shocks, through rehabilitation and maintenance of public or community infrastructure. The aim is to maximize local employment while rehabilitating productive infrastructure assets, which have potential to: (a) generate local secondary employment effects; and (ii) protect households and communities against Page 7 external shocks. The component will establish a LIPW-based social protection scalable instrument that provides quick-response mechanisms against external shocks, such as floods or droughts, during a crisis. The payment modality for LIPWs will be cash. The scope of works eligible for LIPWs will be defined based on their labor content and scope to generate significant local employment. The poor state of infrastructure remains a major obstacle to economic development in rural areas, especially in the northern regions. For example, it has been estimated that about 60 percent of the 11,800km of rural roads and a majority of over 900 small (earth) dams and dugouts in the three northern regions are in poor to fair condition. It is expected that LIPWs will target mainly the following assets that are both highly appreciated by communities and allow for timing of labor inputs during the dry season: # Rehabilitation and maintenance of rural feeder and access roads: Although the #utility# value of access roads was not rated as highly as dams, the fact that the labor opportunities made available are sufficient to allow for people to plan a dry season #at home# is highly appreciated, as well as the possibility of earning sufficient cash to strengthen the base of household livelihoods. # Rehabilitation of small dams and related public infrastructure: Where dams allow for dry season irrigated agriculture, it has a dramatic impact on local livelihoods, greatly reducing the incentive to migrate away from the region during the dry season. # Dugouts are of great significance in much of the northern region, where underground water sources are insufficient to provide for domestic and livestock needs through the dry season. The LIPWs will be selected from the Medium-Term District Development Plans (MTDDPs) and/or related Area Council Action Plans (ACAPs) based on a set of criteria to: (a) maximize rural employment (high labor content); (ii) create or rehabilitate public or collective (i.e., community) assets; (iii) create or rehabilitate productive assets capable of generating secondary employment and economic development within local communities; (iv) undertake LIPWs within reasonable proximity of target populations; (v) avoid competing with labor demand from the agricultural sector (i.e., appropriate timing); (vi) comply with social and environmental safeguards; and (vii) ensure equal opportunity for women and men to participate. However, it will be necessary to review the MTDDPs and ACAPs in the selected project districts at the start of the project to update them and ensure that the respective project activities would be fully integrated with other ongoing feeder road and small dam rehabilitation activities that may be financed by other sources. In line with government#s ongoing decentralization process, the labor intensive public works will be implemented through District Assemblies and by relevant line agencies like the Department of Feeder Roads, the Government Irrigation Development Agency, the Department of Social Welfare, and the National Disaster Management Organization. Component Three: Livelihood Empowerment Against Poverty Program (LEAP). (US$20 million, including an IDA contribution of US$20 million) The objective of this component is to support the full rollout of the pilot phase of the LEAP program by strengthening its management and administration, improving targeting, and by providing incentives to ensure that GOG's annual budget allocations are sufficient. Page 8 There is recognition within the government and among the partners of the need to build additional capacity within the LEAP administration at the national, regional, district, and community levels to (i) allow for the rapid expansion of the program and (ii) adjust the program to better target the neediest. To this extent, an operational review of LEAP early in 2010 will prepare an Action Plan. DFID, USAID, and UNICEF are expected to support this action plan in the fields of capacity building to improve performance and effectiveness of the implementing agencies, as well as strengthening accountability. The project would also contribute in the form of additional complementary support by providing equipment, training, monitoring and evaluation support, and any additional technical support necessary to improve management, targeting, and the use of Information and Communication Tools (ICTs). Furthermore, the project will specifically aim to improve targeting of LEAP and its self-help aspect by supporting stronger enforcement of human development requirements#especially for households with children of school age. SOP will take the long view of building a nimble and flexible LEAP operation in order to meet national emergencies such as food shortages and famine. In addition, the project will finance incentive payments to the unified treasury account to assure that GOG each year allocates sufficient budget for LEAP to meet its target of 164,370 households by 2012, and will thereby contribute to the improved human capital outcomes for these households. This will be done through conditional Disbursement- Linked Incentives, which will include: (i) success in reaching the target households as evidenced by actual expenditures; and (ii) progress on implementing the Action Plan for LEAP. To ensure that these expenditures are mainstreamed into the GOG budget, the IDA-DLI payments will not exceed one-third of the actual budget expenditures in any given year of the LEAP program. Component Four: Capacity Building. (US$5.4 million, including an IDA contribution of US$5.4 million) The objective of this component is to create capacity at the national and local levels to implement the NSPS in selected project districts, with the view of enabling a gradual scaling-up and targeting at the national level. This component will therefore implicitly strengthen GOG#s decentralization program. Five distinct sets of capacity-building activities will be supported. Establishing a LIPW supportive policy and institutional framework (US$260,000). The project will support GOG to amend and adapt the existing policy and regulatory framework to stimulate a wider use of labor-based methods, both as social protection and infrastructure-generation mechanisms. The following specific activities will be undertaken: (i) a detailed review of the current policy and regulatory framework as it relates to labor based methods; (ii) national consultations with all relevant stakeholders; (iii) drafting of a new framework and a new bill on labor-based methods, to be presented to Parliament for approval; and (iv) an information and sensitization campaign, at the national and regional levels, for decision-makers, concerned private operators, and the population at-large. Capacity building to support LIPW implementation (US$1,410,000) is aimed at decision-makers, DA technical staff, relevant line agencies, and private contractors and follows the below breakdown: Page 9 # Rehabilitation and maintenance of roads (US$1,410,000): The project will support the re-establishment of the training program for contractors and relevant district and regional road engineers by the Koforidua Training Center, which was recently renovated, and the terms of reference for course designs have already been prepared by the International Labor Organization (ILO); and # Rehabilitation of small dams and water storage infrastructure (US$100,000): The project will support limited dam and irrigation design and construction training to complement that being planned for 2010 under the IFAD-AfDB#funded Northern Rural Growth Project (NRGP). Capacity building to support implementation of LEAP (US$500,000) to complement ongoing technical support financed by DFID and UNICEF/USAID as needed, with the objective of strengthening and improving the targeting and monitoring of the government#s social protection instruments and programs (e.g., LEAP). The project will also support the capacity of the central unit of the Ministry of Employment and Social Welfare to plan, develop, and monitor social protection and District Assemblies to implement the programs. Capacity building for disaster risk management (US$2,350,000). There is a close link between disaster response planning and the utilization of social safety nets to effectively respond to the needs of those who are affected. The project will therefore support a series of inter-related capacity-building activities in the three northern regions and in proposed project districts: (a) strengthening national risk management strategies and institutions; (ii) capacity building for risk and vulnerability assessment, early warning, and contingency planning at the district level; (iii) public awareness raising at the district and community levels; and (iv) strengthening of emergency preparedness and response at the local and community levels. The activities supported by the project would be part of the overall national program of the Global Facility for Disaster Reduction and Recovery (GFDRR) and would be integrated in its medium-term and annual work plans. District and regional capacity building (US$750,000) to strengthen the technical and management capacities of the three Regional Coordinating Committees (RCCs), ten to fifteen District Assemblies (DAs), and at least two Area Councils (ACs) in each of the selected districts to: (i) identify, prioritize, and plan their development needs, in particular in terms of rural infrastructure and disaster risk management; and (ii) strengthen fiduciary capacities (i.e., financial management, procurement, and monitoring and evaluation). Capacity-building support will be implemented through on-the-job-training and specific short training courses tailored to the needs of RCCs and DAs. Component Five: Project Management and Coordination. (US$6 million, including an IDA contribution of US$5.8 million) The institutions, structures, and capacities of the Government of Ghana will serve as the foundation for project management and coordination. With the aim of bolstering GOG operations, the Social Opportunities Project will fund costs associated with: project management and coordination; relevant technical assistance; project monitoring and evaluation; consultancy services; communication and training; equipment and vehicles; and incremental operating costs. In addition, the component will include the cost of annual impact evaluation surveys, including a baseline study and an end-of-the-project comprehensive impact evaluation study (US$1 million). Page 10 4. Project Location and salient physical characteristics relevant to the safeguard analysis 22. Three of the administrative regions in the Northern Savannah Zone: Upper East Region, Upper West Region, and Northern Region. 5. Environmental and Social Safeguards Specialists Ms Nyaneba E. Nkrumah (AFTEN) Ms Beatrix Allah-Mensah (AFTCS) 6. Safeguard Policies Triggered Yes No Environmental Assessment (OP/BP 4.01) X Natural Habitats (OP/BP 4.04) X Forests (OP/BP 4.36) X Pest Management (OP 4.09) X Physical Cultural Resources (OP/BP 4.11) X Indigenous Peoples (OP/BP 4.10) X Involuntary Resettlement (OP/BP 4.12) X Safety of Dams (OP/BP 4.37) X Projects on International Waterways (OP/BP 7.50) X Projects in Disputed Areas (OP/BP 7.60) X II. Key Safeguard Policy Issues and Their Management A. Summary of Key Safeguard Issues 1. Describe any safeguard issues and impacts associated with the proposed project. Identify and describe any potential large scale, significant and/or irreversible impacts: Social: The World Banks ASPEN environmental screening identified the project as category B. This means that impacts are likely to occur but such impacts can be mitigated or avoided altogether. To this extent, the project triggered four safeguards policies: (i) the involuntary resettlement, OP/BP 4.12, (ii) the Environmental Assessment, OP/BP 4.01 and(iii)Safety of Dams OP/BP 4.37.For these triggered policies, the Government of Ghana has prepared a Resettlement Policy Framework (RPF) and an Environmental and Social Management Framework (ESMF. A Dam safety report for the rehabilitation of existing dams will be done shortly. The main purpose of the RPF is to clarify applicable resettlement principles, organizational arrangements, and design criteria. Its objectives are consistent with avoiding or minimizing involuntary resettlement or land acquisition where possible; where unavoidable, ensuring that compensation and resettlement are designed and implemented with sustainability as the prime focus; and ensuring that affected persons are supported to improve their livelihood or at least restore them to pre-displacement levels. The RPF therefore sets out the legal and administrative framework, which includes the systems of land ownership and tenure as well as the socio-economic characteristics of beneficiary districts. It also details the consultation processes, eligibility criteria, and methodology for valuation of assets and a clear entitlement policy and compensation payment processes. In order to ensure that implementation of the RPF is on Page 11 course and accountability aligned, the RFP has articulated monitoring and evaluation with clear delineations of monitoring indicators and the responsibilities of agencies. The RPF outlined sections on organizational arrangements for implementation and monitoring and a template for the design of a resettlement action plan should that become necessary after identification of exact project sites or locations. The project will prepare a resettlement action plan or an abbreviated resettlement action plan (given the number of affected people) if land-seizure, displacement, or resettlement occurs or when peoples livelihoods are affected due to limited access to assets or source of livelihood during implementation. The RPF outlines measures for building the capacity of officials responsible for implementing the RPF. Environment. The environmental impacts of the project cut across the pre-construction, construction, and post-construction phases of sub-project implementation. The environmental analysis indicates that most negative impacts are likely to be minimal and largely related to the construction phase. These impacts include air and dust emissions, noise and vibration, open pits/trenches, disposal of construction waste, and public safety/health concerns. The project will also fund the rehabilitation of small dams, and the safety of these dams, pre- and post-rehabilitation, will need to be technically assessed. The dams, however, are small, pre-existing dams, and the borrower will arrange for an independent dam specialist to: (i) inspect and evaluate the safety status of the existing dam, its appurtenances, and its performance history; (ii) review and evaluate the owner's operation and maintenance procedures; and (iii) provide a written report of findings and recommendations for any remedial work or safety-related measures necessary to upgrade the existing dam to an acceptable standard of safety. For small dams such as the ones in this project (less than 15 m), generic dam safety measures designed by qualified engineers are adequate. Other negative impacts related to dams include siltation and the modification of flow of water courses, stream drainage issues, and possible water quality degradation. The ESMF has included a set of mitigation measures to address these issues, and where the negative impact may be more serious, an environmental management plan (EMP) will be developed as indicated in the ESMF to address the impacts. The ESMF addresses both Ghanian and World Bank requirements. Of the former, the legal, policy, and administrative framework are enumerated at the national level. The latter covers safeguard policies as well as descriptions of environmental and social baseline conditions. The ESMF also discusses the potential social and environmental impacts and the screening processes for identifying these impacts. To avert or minimize these impacts before, during, and after sub-project implementation, the ESMF outlines mitigation measures for each possible negative impact and the costs associated with mitigation and safeguard training, and a list of responsible actors within the ministries to monitor compliance. In terms of mitigation, the ESMF contains draft environmental and social clauses that will be used by the project to ensure that the contractor complies with environmental and social safeguards in the project. In addition, prior to any construction work, the ESMF also provides an environmental screening checklist that should be used for every sub-project to identify potential negative impacts prior to construction. The district engineer, with support from the EPA, will be responsible for ensuring that contractors comply with environmental mitigation measures put in place to minimize any negative impact (e.g., dust, noise, and Page 12 land erosion/degradation) that may disturb the natural habitat. To ensure this, further checklists and monitoring will occur by an environmental specialist (assigned or recruited). Finally, reporting to the project and the Bank will ensure oversight of mitigation measures. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area: The initial assessment noted that the project will have more positive than negative social impacts. With the positive impact, it is noted that the project will bring about cohesion in the community and serve as a rallying point for communities benefitting from the project to begin engaging in more empowering processes for themselves as individuals and for their communities as a whole. It will lead to income for the individuals which will translate into the wider community during the agricultural off-season and reduce the level of vulnerabilities. This can increase the potential for social capital and build stronger communities, which will contribute to ownership and sustainablility. In addition, the project has the potential of curbing the youth migration to the South as an annual affair due to the habitual lean agricultural season. On the negative side, the potential exists for tension between adjacent communities where one is benefiting and not the other. Similarly, the expectation from communities could be overly high with regard to the overall benefit from the project at the individual and community levels. The ESMF has outlined measures to address these issues, among others including sensitization, information dissemination, and participation and inclusion of beneficiaries or their representatives at every stage of the project preparation and implementation. These steps will ensure that the possible negative impacts are not only mitigated but are in fact positively harnessed for overall benefits. The social assessment exercises carried out to inform the project design suggested that all the selected activities under the LEAP and LIPW components will address compelling problems of poverty in northern Ghana. At the same time, there are many poor people in northern Ghana who will still fall outside of the reach of these pilot efforts. Most poor people in northern Ghana rely on kin, community, or civil society organizations for such support as they receive to help them recover from shocks and cope with seasonal deprivation. This emphasizes the importance of the work to be done in strengthening the architecture of social protection under Component 1. 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. The alternative to the World Bank participating in the Ghana Social Opportunities Project would be: (i) that less of these environmentally beneficial works would be undertaken or: (ii) they would be undertaken without the need for compliance with World Bank environmental or social safeguards. 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 Ministry of Local Government and Rural Development (MLGRD) has overall responsibility for the project, yet the implementation of component activities will be handled by different agencies, including District Assemblies (DAs) and the National Page 13 Disaster Management Organization (NADMO). By implementing the Community-Based Rural Development Project (CBRDP), the MLGRD has acquired a level of capacity in safeguards as per World Bank policy requirements. Under the CBRDP and in collaboration with the Environmental Protection Agency (EPA) of Ghana, the MLGRD developed a manual to train selected District Assembly officials while processing the environmental impact assessment for sub-projects at the community level. While this is commendable, it is not sufficient to ensure safeguards compliance by the SOP. The ESMF and RPF have identified capacity-building activities for the various key stakeholders to ensure understanding of safeguards and application of implementation and monitoring measures to achieve sustainability and to avoid or reduce negative impacts. For both the RPF and ESMF, a budget estimate for the required training and capacity building has been included. This training will cover staff at the local, district, and even national level. The combination of an agency well-versed in national and World Bank safeguard policies and requirements (i.e., EPA-Ghana) and ministries with on-the- ground experience in projects similar to the SOP fosters a solid working relationship. 35. During the preparation of the ESMF and RPF, there was extensive consultation with stakeholders at the national, district, and community level. These included staff of the CBRDP at the national level, District Assembly officials, and community opinion leaders, including chiefs and ordinary citizens. The process for preparing these safeguards documents requires consultations and information disclosure. 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. Approximately 100 individual were consulted during the preparation of the RPF. The main aim of the consultations was to involve potential beneficiaries and sensitize them, solicit their views and inputs, and identify potential impacts and people while assessing the level of safeguards compliance in the three northern regions. The consultations involved group discussions with a number of people, including women and children, and interviews with local institutional heads like District Assembly officials and NGOs. In sum, the project was overwhelmingly viewed as beneficial yet seen to be responsible for implementing measures to compensate those affected (displaced) by it. 37. Additionally, the design of the project was heavily informed by a Participatory Poverty and Vulnerability Assessment (PPVA), supported by DFID, UNICEF, and the World Bank, which was commissioned to inform the design of poverty reduction policies in Ghana with a focus on the North. Two rounds of PPVA fieldwork contributed to the design of the project. Both rounds of work were carried out in twelve communities in northern Ghana: three in the Northern Region, three in the Upper West Region, and six in the Upper East Region. The PPVA also undertook fieldwork in five communities in the south of Ghana, with a focus on northern migrants working outside of their home area. 38. In relation to areas covered by the SOP, the PPVA found strong support in all communities consulted for the provision of dry season income-earning opportunities and productive infrastructure through labor intensive public works. The consulted communities had mixed experiences working with contractors on previous LIPW projects. In some cases, the relationships progressed smoothly while in others, complaints Page 14 arose of contractors failing to pay individuals, harassing workers (including sexual harassment of women), or providing work opportunities at the wrong time of the year. 39. On the basis of the consultations carried out, the following has been concluded: 40. LIPW activities should support large segments of work (e.g., rehabilitation of dams and feeder roads) that provide reasonably large #blocks# of dry season wage labor opportunities to the beneficiaries (meaning an average of at least 20 days per person between November and March/April). It should undertake the kinds of projects that communities are accustomed to doing with unpaid communal labor (e.g., rehabilitating school blocks and clinics). Through adopting the approach of only paying for labor when it is beyond the scale that voluntary self-help activities can provide, the project should avoid the risk of undermining important traditions of community self-help. The strong preference for supporting activities that provide a major block of labor is also due to the perception that a sufficient incentive is needed to prevent young men and women from leaving on seasonal labor migration to the south of Ghana. 41. Projects should reflect community preferences. On the basis of the fieldwork carried out in the PPVA and the pre-appraisal mission the menu includes: small dams, dugouts, and access roads. 42. Communities should be involved in managing the distribution of work opportunities. Given the high general incidence of poverty in northern Ghana - and the intention to use area-based targeting of poor areas within the North for LIPW - the recommended approach to target households at the community level is to ensure a fair distribution of opportunities between all those who can work and wish to take part. Consultations carried out through the PPVA and the pre-appraisal mission confirmed a strong preference for the community itself to be involved in overseeing the distribution of opportunities for work. The communities placed a high value on transparency and involving community institutions in assuring accountability. Two elements are recommended: (i) a community meeting to establish the principles for allocating work opportunities and (ii) using the unit committee to oversee the execution of what has been decided. All of this is in line with existing practices for managing the distribution of opportunities within communities according to locally recognized norms of fairness and transparency. 43. On the whole the project preparation studies revealed that gender bias should not be a major problem as opportunities for females and males in public works tend to be well balanced. 44. The PPVA found a very limited impact or awareness of public safety nets. The main findings in relation to LEAP are that: (i) its outreach remains very limited among the poor in northern Ghana; (ii) the primary use of the LEAP grant is for food, although the teams also found instances where money was used to purchase small animals, pay NHIL, or purchase school uniforms; and (iii) a perception existed in the two communities where specific research on LEAP was conducted that the selection process favored contacts of the #local agent# and did not reach the most vulnerable. The delivery of more robust livelihood options to the working poor in northern Ghana through LIPW can, therefore, be expected to have a positive impact on enhancing the livelihood security of the non-working poor on communities where benefits are delivered. Page 15 B. Disclosure Requirements Date Environmental Assessment/Audit/Management Plan/Other: Was the document disclosed prior to appraisal? Yes Date of receipt by the Bank 01/18/2010 Date of "in-country" disclosure 01/29/2010 Date of submission to InfoShop 01/27/2010 For category A projects, date of distributing the Executive Summary of the EA to the Executive Directors Resettlement Action Plan/Framework/Policy Process: Was the document disclosed prior to appraisal? Yes Date of receipt by the Bank 01/27/2010 Date of "in-country" disclosure 02/16/2010 Date of submission to InfoShop 02/11/2010 Indigenous Peoples Plan/Planning Framework: Was the document disclosed prior to appraisal? Date of receipt by the Bank Date of "in-country" disclosure Date of submission to InfoShop Pest Management Plan: Was the document disclosed prior to appraisal? Date of receipt by the Bank Date of "in-country" disclosure Date of submission to InfoShop * If the project triggers the Pest Management and/or Physical Cultural Resources, 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 (to be filled in when the ISDS is finalized by the project decision meeting) OP/BP/GP 4.01 - Environment Assessment Does the project require a stand-alone EA (including EMP) report? Yes If yes, then did the Regional Environment Unit or Sector Manager (SM) review and approve the EA report? Yes Are the cost and the accountabilities for the EMP incorporated in the credit/loan? Yes OP/BP 4.12 - Involuntary Resettlement Has a resettlement plan/abbreviated plan/policy framework/process framework (as appropriate) been prepared? Yes If yes, then did the Regional unit responsible for safeguards or Sector Manager review the plan? Yes Page 16 OP/BP 4.37 - Safety of Dams Have dam safety plans been prepared? No Have the TORs as well as composition for the independent Panel of Experts (POE) been reviewed and approved by the Bank? N/A Has an Emergency Preparedness Plan (EPP) been prepared and arrangements been made for public awareness and training? N/A The World Bank Policy on Disclosure of Information Have relevant safeguard policies documents been sent to the World Bank's Infoshop? Yes Have relevant documents been disclosed in-country in a public place in a form and language that are understandable and accessible to project-affected groups and local NGOs? Yes All Safeguard Policies Have satisfactory calendar, budget and clear institutional responsibilities been prepared for the implementation of measures related to safeguard policies? Yes Have costs related to safeguard policy measures been included in the project cost? Yes Does the Monitoring and Evaluation system of the project include the monitoring of safeguard impacts and measures related to safeguard policies? Yes Have satisfactory implementation arrangements been agreed with the borrower and the same been adequately reflected in the project legal documents? Yes D. Approvals Signed and submitted by: Name Date Task Team Leader: Mr Qaiser M. Khan 02/18/2010 Environmental Specialist: Ms Nyaneba E. Nkrumah 02/18/2010 Social Development Specialist Ms Beatrix Allah-Mensah 02/18/2010 Additional Environmental and/or Social Development Specialist(s): Mr John William Fraser III Approved by: Sector Manager: Ms Lynne D. Sherburne-Benz 02/18/2010 Comments: