FOR OFFICIAL USE ONLY
Report No: PAD00213
INTERNATIONAL BANK FOR RECONSTRUCTION AND DEVELOPMENT
PROJECT APPRAISAL DOCUMENT
ON A
PROPOSED GRANT
FROM THE
GLOBAL ENVIRONMENT FACILITY
IN THE AMOUNT OF US$13.49 MILLION
WITH CO-FINANCING FROM THE
IRAQ REFORM, RECOVERY AND RECONSTRUCTION FUND
IN THE AMOUNT OF US$5 MILLION
TO THE
REPUBLIC OF IRAQ
FOR
INTEGRATED PERSISTENT ORGANIC POLLUTANTS (POPS) AND CHEMICAL HOTSPOTS MANAGEMENT PROJECT
(P178935)
JANUARY 29, 2025
Environment, Natural Resources & the Blue Economy
Middle East And North Africa
This document has a restricted distribution and may be used by recipients only in the performance of their official
duties. Its contents may not otherwise be disclosed without World Bank authorization.
CURRENCY EQUIVALENTS
(Exchange Rate Effective {January 1, 2025})
Currency Unit = US$
1309.998 IQD = US$1
FISCAL YEAR
January 1 - December 31
Regional Vice President: Ousmane Dione
Regional Director: Meskerem Brhane
Country Director: Jean-Christophe Carret
Practice Manager: Maria Sarraf
Task Team Leader(s): Harinath Sesha Appalarajugari, Ahmed Ali
ABBREVIATIONS AND ACRONYMS
CPF Country Partnership Framework
EHS Environment, Health, and Safety
ESCP Environmental and Social Commitment Plan
ESF Environmental and Social Framework
ESS Environmental and Social Standards
FM Financial Management
GA Grant Agreement
GAP Gender Action Plan
GEF Global Environment Facility
GDP Gross Domestic Product
GHG Greenhouse Gas
GM Grievance Mechanism
GoI Government of Iraq
GRS Grievance Redress Service
IFC International Finance Corporation
IFR Interim Financial Report
IPF Investment Project Financing
IPOPs Industrial Persistent Organic Pollutants
IQD Iraqi Dinar
I3RF Iraq Reform Recovery Reconstruction Fund
KRI Kurdistan Region of Iraq
M&E Monitoring and Evaluation
MoA Ministry of Agriculture
MoElec Ministry of Electricity
MoEn Ministry of Environment
MoO Ministry of Oil
NDCs Nationally Determined Contributions
NIP National Implementation Plan
NPCSM National Program on Contaminated Sites Management
OPs Obsolete Pesticides
PCB Polychlorinated Biphenyls
PDO Project Development Objective
PFS Project Financial Statement
PMU Project Management Unit
POM Project Operations Manual
POPs Persistent Organic Pollutants
PPSD Project Procurement Strategy for Development
PSC Project Steering Committee
SEA/SH Sexual Exploitation and Abuse and Sexual Harassment
SDGs Sustainable Development Goals
STEP Systematic Tracking of Exchanges in Procurement
TPMA Third Party Monitoring Agency
UNDP United Nations Development Program
UNEP United Nations Environment Program
UPOPs Unintentional Persistent Organic Pollutants
WBG World Bank Group
The World Bank
Integrated Persistent Organic Pollutants (POPs) and Chemical Hotspots Management Project (P178935)
TABLE OF CONTENTS
DATASHEET ........................................................................................................................... ii
I. STRATEGIC CONTEXT ...................................................................................................... 1
A. Country Context ................................................................................................................................ 1
B. Sectoral and Institutional Context .................................................................................................... 1
C. Relevance to Higher Level Objectives ............................................................................................... 3
II. PROJECT DESCRIPTION.................................................................................................... 4
A. Project Development Objective ........................................................................................................ 4
B. Project Components ......................................................................................................................... 4
C. Project Beneficiaries ......................................................................................................................... 8
D. Results Chain..................................................................................................................................... 9
E. Rationale for Bank Involvement and Role of Partners ...................................................................... 9
F. Lessons Learned and Reflected in the Project Design ..................................................................... 10
III. IMPLEMENTATION ARRANGEMENTS ............................................................................ 10
A. Institutional and Implementation Arrangements ........................................................................... 10
B. Results Monitoring and Evaluation Arrangements ......................................................................... 11
C. Sustainability ................................................................................................................................... 12
IV. PROJECT APPRAISAL SUMMARY ................................................................................... 12
A. Technical, Economic and Financial Analysis (if applicable) ............................................................. 12
Paris Alignment and Climate Change................................................................................ 14
Gender .............................................................................................................................. 15
Citizen Engagement .......................................................................................................... 15
Private Sector Engagement............................................................................................... 16
B. Fiduciary .......................................................................................................................................... 16
C. Legal Operational Policies ............................................................................................................... 18
D. Environmental and Social ............................................................................................................... 18
V. GRIEVANCE REDRESS SERVICES ..................................................................................... 19
VI. KEY RISKS...................................................................................................................... 19
VII. RESULTS FRAMEWORK AND MONITORING ................................................................... 22
ANNEX 1: Implementation Arrangements and Support Plan & Economic Analysis ................ 27
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Integrated Persistent Organic Pollutants (POPs) and Chemical Hotspots Management Project (P178935)
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DATASHEET
BASIC INFORMATION
Project
Operation Name
Beneficiary(ies)
Iraq Integrated Persistent Organic Pollutants (POPs) and Chemical Hotspots Management Project
Environmental and Social Risk
Operation ID Financing Instrument
Classification
Investment Project
P178935 High
Financing (IPF)
GEF Focal Area
Persistent Organic Pollutants
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Financing & Implementation Modalities
[ ] Multiphase Programmatic Approach (MPA) [ ] Contingent Emergency Response Component (CERC)
[ ] Series of Projects (SOP) [✓] Fragile State(s)
[ ] Performance-Based Conditions (PBCs) [ ] Small State(s)
[ ] Financial Intermediaries (FI) [ ] Fragile within a non-fragile Country
[ ] Project-Based Guarantee [ ] Conflict
[ ] Deferred Drawdown [ ] Responding to Natural or Man-made Disaster
[ ] Alternative Procurement Arrangements (APA) [ ] Hands-on Expanded Implementation Support (HEIS)
Expected Approval Date Expected Closing Date
20-Feb-2025 31-Dec-2031
Bank/IFC Collaboration
No
Proposed Development Objective(s)
Improve the management and safe disposal of Persistent Organic Pollutants (POPs) and hazardous chemicals in Iraq.
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Integrated Persistent Organic Pollutants (POPs) and Chemical Hotspots Management Project (P178935)
Components
Component Name Cost (US$)
Improving the management framework for POPs and hazardous chemicals 5,000,000.00
Management and disposal of high-risk priority stockpiles of POPs in
7,900,000.00
agriculture and power sectors
Management of chemical pollution hotspots 4,850,000.00
Project management, Monitoring and Evaluation 737,495.00
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Organizations
Borrower: Republic of Iraq
Contact Title Telephone No. Email
Implementing Agency: Ministry of Environment
Contact Title Telephone No. Email
Raghad Asad Alobaidi Dr. +964 7711112231 env.alobaidi@yahoo.com
Ali Wahab Ahmed Mr +964 7822208738 moen.iraq@gmail.com
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PROJECT FINANCING DATA (US$, Millions)
Maximizing Finance for Development
Is this an MFD-Enabling Project (MFD-EP)? No
Is this project Private Capital Enabling (PCE)? No
SUMMARY
Total Operation Cost 18.48
Total Financing 18.48
Financing Gap 0.00
DETAILS
Non-World Bank Group Financing
Trust Funds 18.48
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Integrated Persistent Organic Pollutants (POPs) and Chemical Hotspots Management Project (P178935)
Iraq Reconstruction Trust Fund 5.00
Global Environment Facility (GEF) 13.48
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Expected Disbursements (US$, Millions)
WB Fiscal
Year 2025 2026 2027 2028 2029 2030 2031 2032
Annual 0.00 5.00 2.50 2.99 2.50 2.50 2.00 1.00
Cumulativ
e 0.00 5.00 7.50 10.49 12.99 15.49 17.49 18.49
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PRACTICE AREA(S)
Practice Area (Lead) Contributing Practice Areas
Environment, Natural Resources & the Blue Economy Agriculture and Food; Energy & Extractives
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SYSTEMATIC OPERATIONS RISK- RATING TOOL (SORT)
Risk Category Rating
1. Political and Governance ⚫ High
2. Macroeconomic ⚫ Moderate
3. Sector Strategies and Policies ⚫ Moderate
4. Technical Design of Project or Program ⚫ Substantial
5. Institutional Capacity for Implementation and Sustainability ⚫ Substantial
6. Fiduciary ⚫ High
7. Environment and Social ⚫ High
8. Stakeholders ⚫ Substantial
9. Other ⚫ High
10. Overall ⚫ Substantial
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Integrated Persistent Organic Pollutants (POPs) and Chemical Hotspots Management Project (P178935)
POLICY COMPLIANCE
Policy
Does the project depart from the CPF in content or in other significant respects?
[ ] Yes [✓] No
Does the project require any waivers of Bank policies?
[ ] Yes [✓] No
ENVIRONMENTAL AND SOCIAL
Environmental and Social Standards Relevance Given its Context at the Time of Appraisal
E & S Standards Relevance
ESS 1: Assessment and Management of Environmental and Social Risks and
Relevant
Impacts
ESS 10: Stakeholder Engagement and Information Disclosure Relevant
ESS 2: Labor and Working Conditions Relevant
ESS 3: Resource Efficiency and Pollution Prevention and Management Relevant
ESS 4: Community Health and Safety Relevant
ESS 5: Land Acquisition, Restrictions on Land Use and Involuntary Resettlement Not Currently Relevant
ESS 6: Biodiversity Conservation and Sustainable Management of Living Natural
Not Currently Relevant
Resources
ESS 7: Indigenous Peoples/Sub-Saharan African Historically Underserved
Not Currently Relevant
Traditional Local Communities
ESS 8: Cultural Heritage Not Currently Relevant
ESS 9: Financial Intermediaries Not Currently Relevant
NOTE: For further information regarding the World Bank’s due diligence assessment of the Project’s potential
environmental and social risks and impacts, please refer to the Project’s Appraisal Environmental and Social Review
Summary (ESRS).
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LEGAL
Legal Covenants
Sections and Description
Schedule 2, Section I.A.3: The Recipient shall establish not later than three (3) months after the Effective Date or any
later date as agreed by the Bank, the Project Steering Committee and thereafter shall maintain its participation,
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Integrated Persistent Organic Pollutants (POPs) and Chemical Hotspots Management Project (P178935)
throughout the Project implementation period, in said Project Steering Committee with composition, mandate and
resources satisfactory to the Bank, to be comprised of, inter alia, representatives of the Recipient’s ministries
responsible for finance and local government.
Schedule 2, Section I.C.1: To facilitate the implementation of the Project, the Recipient shall by not later than three (3)
months after the Effective Date or such later date as the Bank may agree in writing, cause the PIE to prepare and adopt
the POM for the Project, in form and substance acceptable to the Bank.
Schedule 2, Section I.D.6: The Recipient shall establish by not later than one (1) month after the Effective Date, or such
later date as the Bank may agree in writing, publicize, maintain and operate an accessible grievance mechanism, to
receive and facilitate resolution of concerns and grievances of Project-affected people, and take all measures necessary
and appropriate to resolve, or facilitate the resolution of, such concerns and grievances, in a manner acceptable to the
Bank.
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Conditions
Type Citation Description Financing Source
GEF Grant Agreement,
Article IV, Section 4.01: This
Agreement shall not
become effective until
GEF GA, Article IV, Section execution and delivery of
Effectiveness Trust Funds
4.01 this Agreement on behalf
of the Recipient have been
duly authorized or ratified
by all necessary
governmental action.
I3RF Grant Agreement,
Article IV, Section 4.01: The
I3RF Grant Agreement has
been executed and
delivered and all conditions
I3RF GA, Article IV, Section precedent to its
Effectiveness Trust Funds
4.01 (b) effectiveness or to the right
of the Recipient to make
withdrawals under it (other
than the effectiveness of
this Agreement) have been
fulfilled
GEF GA, Schedule 2, Section
III.B.1(b) / I3RF GA,
GEF GA, Schedule 2, Section
Schedule 2, Section
III.B.1(b) / I3RF GA,
Disbursement III.B.1(b): Notwithstanding Trust Funds
Schedule 2, Section
the provisions of Part A of
III.B.1(b)
this Section no withdrawal
shall be made under
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Integrated Persistent Organic Pollutants (POPs) and Chemical Hotspots Management Project (P178935)
Category (2) unless and
until the Recipient has
entered into the Output
Agreement with the Project
Implementing Entity, under
terms and conditions
satisfactory to the Bank.
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Integrated Persistent Organic Pollutants (POPs) and Chemical Hotspots Management Project (P178935)
I. STRATEGIC CONTEXT
A. Country Context
1. Iraq is an upper middle-income country, with poverty rate of about 20 percent. Almost two decades after series
of conflicts, the country remains caught in a fragility trap with political instability, geopolitical risks, and volatile
financial position. These events have had significant economic and social impacts on the country. The COVID 19
pandemic also induced a recession in 2020, and the country’s economy contracted for the second consecutive
year in 2024 (0.70 percent) due to constrained crude oil production. However, according to International Monitory
Fund, the real GDP is expected to recover in 2025 and is projected to grow at 4.1%.
2. Successive conflicts significantly damaged Iraq’s oil and industrial assets. This resulted in air, land, and water
pollution on an unprecedented scale. Water pollution and land contamination have a long-lasting impact on the
safety, health, and livelihoods of communities and disproportionately impact the most vulnerable, who are more
reliant on natural resources for their livelihoods. These groups in Iraq include an estimated 3 million internally
displaced population, women, female-headed households, and the youth. Although the full extent of conflict-
related land contamination in the country is yet to be confirmed, the Damage Needs Assessment, 20181 of the
World Bank estimated that about 2.4 million hectares of high-use land has been rendered unusable due to land
mines, and that an additional 10,600 hectares have been lost due to pollution of hydrocarbons and other
chemicals. The extent of both surface and groundwater contamination has also not been assessed. In this context,
concrete measures to improve environmental management capacity of the government and addressing the issues
of chemical pollution are needed to reduce the exposure of population to hazards and health risks and to improve
environmental quality.
3. In the light of these challenges, Government of Iraq (GoI) is paying high attention to environmental issues.
Accordingly, the National Development Plan 2024-28, identifies declining environment quality in the country as
an important challenge and includes a specific chapter on Environmental Sustainability and Climate Change. The
plan under the environment chapter includes a specific objective on ‘Waste and Hazardous waste management’.
The GoI has also enhanced its collaboration with the international community on environment related matters.
The Ministry of Environment (MoEn), in particular, is playing an important role in its commitment to international
environmental policies and cooperation in partnership with various international development organizations.
B. Sectoral and Institutional Context
4. The impact of chemical pollution on human health is devastating. Human exposure to chemical pollution
(particularly women, children, and vulnerable groups) even at low levels can cause significant negative effects on
human health. Studies by the Stockholm Convention2 and others establish the vulnerability of women to chemical
contamination and the potential of bio-accumulative chemicals to pass from mother to baby from utero and via
breast milk. This leads to critical health impacts such as breast cancer on women and child growth impairment.
1 World Bank. 2018. “Damage and Needs Assessment of Affected Governorates.” Part 2 of “Iraq Reconstruction & Investment.”
https://openknowledge.worldbank.org/entities/publication/8ba990ba-26d9-59aa-bfd6-6591250bb588.
2 https://chm.pops.int/Implementation/GlobalMonitoringPlan/MonitoringActivities/Humanmilksurvey/tabid/270/Default.aspx
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5. Of all chemicals Persistent Organic Pollutants (POPs) are among the most dangerous. They persist in the
environment and accumulate in living organisms through the food chain, making them highly toxic to humans and
wildlife. These POPs are categorized into four categories: Obsolete Pesticides (OPs), Polychlorinated Biphenyls
(PCBs), Un-intentional POPs (UPOPs) and Industrial POPs (IPOPs). OPs are mostly found in the agriculture sector,
PCBs are used in the power sector, UPOPs are emitted due to incomplete combustion processes from burning of
solid waste, electronic waste, hazardous waste, etc. and IPOPs are used in industrial processes and activities.
6. An assessment of chemical pollution hotspots by The World Bank and MoEn in seven conflict affected
governorates identified 76 sites impacted by oil and chemical pollution directly affecting 55,050 people and 1.7
million people indirectly3. The assessment estimated economic loss of this pollution as US$1.4 billion per year due
to health, economic, agriculture and livelihood impacts on people and recommended a national program on
chemical pollution and contaminated sites. The assessment also recommended establishment of a platform to
engage with civil society and citizens, build community awareness and solicit feedback on chemical pollution.
7. The GoI initiated regulatory and institutional actions to address the issues of chemical pollution and
contaminated sites. These efforts include the passage of major environmental legislations such as Law No. 27 of
2009 on Protection and Improvement of the Environment including management of chemicals and hazardous
waste. MoEn has also established ‘chemicals monitoring and contaminated sites assessments department’ to
conduct inspections, assessments, and monitor implementation of management measures. However, the
technical capacity and basic infrastructure of the department managing chemical pollution requires
strengthening.
8. Iraq is signatory to international conventions and agreements on chemicals and hazardous substances, such as
(i) the Basel Convention on the Control of Transboundary Movement of Hazardous Wastes and their Disposal,
1992 (ratified on May 2, 2011), (ii) the Stockholm Convention on Persistent Organic Pollutants, 2004 (ratified on
March 8, 2016), (iii) the Rotterdam Convention on Prior Informed Consent Procedure for Certain Hazardous
Chemicals and Pesticides in International Trade, 2004 (ratified on April 18, 2017), (iv) the Minamata Convention
on Mercury, 2017 (ratified on September 16, 2021). This confirms GoI’s commitment to addressing the challenges
of chemical pollution and enables the country to access technical and financial resources from global mechanisms.
9. In accordance with the Stockholm Convention, Iraq has developed a National Implementation Plan (NIP) 4 for
POPs with technical support from the United Nations Environment Program (UNEP) and funding from the Global
Environment Facility (GEF). The NIP conducted an inventory of POPs comprising of OPs, PCBs and UPOPs and
proposed actions to manage and eliminate POPs. The main findings of the NIP are the following:
(a) Obsolete Pesticides. The Ministry of Agriculture (MoA) operates 18 pesticides storage depots in each
governorate of Iraq, which store all types of pesticides including OPs. Currently, about 4.71 million empty
containers are estimated to have been stored at these depots, including 103 tons of OPs, 421 liters of
Endosulfan and about 142,000 empty containers at Al- Suwaira– a major pesticide storage warehouse.
The laboratory analysis of 20 soil and warehouse surface samples at Al-Suwaira identified five compounds
of OPs. Similar contamination of pesticides and OPs is anticipated at other storage depots of the MoA.
3 World Bank. 2023. “Iraq Environmental Hotspots: Land Remediation for Livelihoods Restoration”.
https://documents.worldbank.org/en/publication/documents-
reports/documentdetail/099102723191012184/p1730490b252b40bd0a2b40df0215e54614
4 Develop the National Implementation Plan for the Stockholm Convention on Persistent Organic Pollutants (POPs) and the Minamata Initial
Assessment for the Minamata Convention on Mercury in Iraq (GEF Project ID 9690)
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(b) PCBs in power sector. The NIP identified the possibility of potential PCB contamination of ‘in-use’
equipment imported before 1989. The inventory also indicated that there are about 230,887 in-service
distribution power transformers (including those in Kurdistan Region of Iraq - KRI), 587 transmission
power transformers (excluding KRI), and 129 production power transformers (including in KRI)
manufactured between 1960 and 1990. It is also anticipated that more than 1 million liters of stored oil,
42 scrap yards, 19,585 scrap transformers and about 8,000 transformers are stored in about 170 locations
across the country. A limited on-site sampling and analysis of 53 random samples using Chlor-N-oil instant
PCBs testing kits concluded that 18 (33 percent) of these samples are PCB positive.
(c) UPOPs. The NIP analyzed nine sources such as waste incineration, production of ferrous and non-ferrous
metals, heat, and power generation, etc. and estimated that about 127,000 g Toxic Equivalent of UPOPs
are generated in Iraq per annum.
10. The NIP however, focused on 30 POPs listed under the Stockholm Convention until 2019 and didn’t focus on
subsequently included IPOPs. In addition, the plan was prepared during COVID 19 period, hence adequate field
inventories and assessments could not be conducted. Accordingly, the NIP recommended its further update based
on detailed inventory of all POPs and necessary policy and institutional actions.
C. Relevance to Higher Level Objectives
11. The Project is aligned with the Country Partnership Framework (CPF) (FY22-FY26) for Iraq and supports the
achievement of Pillar 1: improved governance, public service delivery and private sector participation. The Project
is also aligned with World Bank Group (WBG)’s corporate and regional strategies and the renewed vision of
eliminating poverty in a livable planet. The Project is consistent with the recommendations of Country Climate
and Development Report for Iraq, specifically for health, energy, and waste management sectors and is aligned
with WBG’s proposed Gender Strategy (2024-30).
12. With a focus on hazardous chemicals and contaminated sites, the Project activities are aligned with the
‘National Strategy for the Protection and Improvement of Environment, 2024-30’ and ‘National Development
Plan, 2024-28’ of Iraq. The Project is also consistent with the country’s Nationally Determined Contributions
(NDC). The activities related to OPs management contribute to NDC’s adaptation action on ‘reducing reliance on
pesticides and herbicides’ in the agriculture sector. By improving the management of PCBs in the power sector,
the Project responds directly to the NDC’s mitigation action to ‘increase efficiency of operational processes to
reduce use of fuel and reduce emissions’ in the energy sector.
13. The Project supports the chemical and waste programming objectives of the GEF related to Program 1 on
Industrial Chemicals and Program 2 on Agricultural Chemicals that aim to eliminate POPs based agriculture
chemicals and PCBs. The Project also contributes to the GEF’s knowledge management guiding framework by
facilitating the collection, exchange, and update of relevant knowledge within the participating countries. By
integrating the component on contaminated sites (hotspots) and capacity building activities, the Project supports
Iraq Reform Recovery and Reconstruction Fund (I3RF)’s objective of ‘fostering socio-economic reform, recovery
and reconstruction that complement the effectiveness of government’s programs.
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Integrated Persistent Organic Pollutants (POPs) and Chemical Hotspots Management Project (P178935)
II. PROJECT DESCRIPTION
A. Project Development Objective
PDO Statement
Improve the management and safe disposal of Persistent Organic Pollutants (POPs) and hazardous chemicals in Iraq.
PDO Level Indicators
14. The outcome of the PDO will be monitored through the following indicators.
▪ OPs and PCBs waste destroyed or disposed or contained (metric ton) - 4,000 tons.
▪ Policies and regulations for the management of POPs, hazardous chemicals, and pollution hotspots developed
(number) - Four
▪ Share of POPs monitored through the management information system established through the Project
(percentage)- 50
▪ Direct project beneficiaries (number) - 7,000,000, of which female (percentage) - 49
B. Project Components
15. The Project through grants from the GEF and I3RF will support Iraq to minimize environment and health risks
due to POPs and other chemical pollution hotspots and improve livelihoods of local communities through the
following four components. While Components 1 and 2 support management of POPs with GEF funding,
Component 3 with I3RF funding supports management of chemical pollution hotspots. Component 4 supports
activities related to project management and monitoring.
Component 1: Improve the management of POPs and hazardous chemicals (US$5.00 million GEF Grant)
Sub-component 1.1: Updating National Implementation Plan for POPs (US$2.70 million)
16. This sub-component will finance update/ preparation of inventory of all POPs (OPs, PCBs, UPOPs and IPOPs)
and development of a comprehensive NIP for Iraq including KRI to comply with Article 7 under the Stockholm
Convention, its endorsement and submission to the Convention Secretariat. The preparation of the NIP will involve
(i) ranking actions based on the obligations set out under the Stockholm Convention, risks posed to human health
and the environment in the country, (ii) identifying cost-effective action plans for the newly adopted POPs (IPOPs),
and (iii) revising action plans for the initial POPs listed under the Convention. The NIP will also consider emerging
aspects such as circular economy approaches, green chemistry, extended producer responsibility, green public
procurement, and economic incentives where feasible and appropriate.
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Integrated Persistent Organic Pollutants (POPs) and Chemical Hotspots Management Project (P178935)
Sub-component 1.2: Policy, regulatory and institutional strengthening for POPs management (US$0.40 million)
17. This sub-component will support assessment of policy, institutional and regulatory gaps for the implementation
of the NIP and other requirements for implementing the Stockholm Convention. Based on this assessment, this
sub-component will support development of (i) policies for the prevention and management, (ii) regulations and
standards for ensuring compliance, (iii) monitoring systems for tracking the entire value chain of import,
production, supply, usage, and disposal, (iv) protocols and guidelines for the storage, handling, maintenance, and
usage, (v) framework and guidelines for the risk-based remediation of contaminated sites and (vi) action plan for
community awareness, consultations and citizens engagement on POPs and other hazardous chemical pollution.
To the extent possible, this sub-component will also support the process of approval and implementation of the
above activities, within the Project’s lifetime. Given the health impacts of POPs on women as established by the
Stockholm Convention and other scientific research, special attention will be paid to ensure that gender
dimensions are integrated in these policies and regulations.
18. This sub-component will also support the establishment of a federal coordination committee for the
implementation of the NIP. This will comprise of members from Iraq and KRI involving relevant ministries and
stakeholders dealing with POPs management, experts from non-governmental organizations, academic and civil
society. This committee will provide guidance and recommendations in the development and effective
implementation of policies and strategies related to hazardous chemicals and POPs. The committee will include
at least 30 percent of qualified women representing field experts or women organizations to ensure that different
health risks faced by women and men are addressed while implementing the NIP.
Sub-component 1.3: Capacity building for POPs Management (US$1.90 million)
19. This sub-component will support building capacity of MoEn and other key stakeholders such as MoA, Ministry
of Electricity (MoElec) and KRI, through training, provision of laboratory and / or field equipment and other
support for better management of POPs and chemicals. This involves the following activities.
(a) comprehensive training in the inspection, testing and monitoring; handling, management, treatment,
disposal/ destruction of POPs, and enforcement of regulations.
(b) provision of necessary laboratory equipment to MoA for testing, sampling, and analysis of POPs.
(c) provision of necessary field equipment to MoEn (Iraq and KRI) for inspection, testing, sampling, and
analysis of POPs including PCBs (oil, soil samples and other elements). Considering the complementarity
of capacity needs for POPs and hazardous chemicals, the laboratory capacity of MoEn will be enhanced
through Component 3.
(d) enhance capacity of maintenance workshops of MoElec (Iraq and KRI) for testing of PCBs (oil, soil samples
and other elements), through procurement of PCB/chloride analyzer system to detect and quantify the
presence of PCBs, acquisition of reagents and accessories, training (maintaining workshops, collection,
handling, storage, and transport of PCBs and wastes).
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These activities will be implemented based on a need assessment of each stakeholder agency, ongoing
government and internationally funded similar initiatives and specific equipment and capacity building needs to
be supported through the Project will be finalized accordingly during project implementation.
Component 2: Management and disposal of high-risk priority POPs in agriculture and power sectors (US$7.90
million GEF Grant)
Sub-component 2.1: Management and disposal of OPs in the agriculture sector (US$2.60 million)
20. Building on OPs inventory in sub-component 1.1, this sub-component will identify priority sites, conduct detailed
assessments, understand critical risks, prioritize sites based on the level of contamination and risks, develop
necessary management and destruction/ disposal strategies for a total of 1000 tons of OPs and support their
implementation. The objective is to demonstrate environmentally sound management of OPs, which can be
scaled-up by GoI beyond the Project. Designs and plans will be developed for the identified priority sites to (i)
capture, segregate and contain obsolete pesticide stockpiles and contaminated materials; (ii) undertake physical
recovery, and (iii) package, transport and safe disposal of the recovered stockpiles and contaminated material.
21. Wherever the destruction of contaminated material is identified as a priority due to risk to local communities and
to achieve GEF strategic objectives of maximizing volume of obsolete pesticides eliminated, this sub-component
will support their disposal based on Best Available Technologies/ Best Environmental Practices as defined by
the Stockholm Convention along with required environment management measures. The selection of
destruction/ disposal technologies will rely on the recommendations of the feasibility study to be conducted under
sub-component 1.1 of the Project. Wherever feasible, disposal in country through co-incineration in cement kilns
(which will avoid most Green House Gas – GHG emissions and resulting in minor Carbon dioxide- CO2 emissions)
or development of appropriate facilities will be pursued or a combination of in-country and disposal at
international facilities will be adopted.
Sub-component 2.2: Management and disposal of PCBs in the power sector (US$5.30 million)
22. The inventory of PCBs, their phase out plan and NIP developed in sub-component 1.1 will guide this sub-
component in designing environmentally sound treatment/disposal of the equipment and dielectric fluids that
will be generated from the contaminated equipment or treat such units so that level of contamination is reduced
to below the low POPs limit specified under the Stockholm Convention (50 ppm). The objective of this component
is not just to dispose/ dechlorinate PCBs but to develop a harmonized national regulatory and administrative
framework for PCBs and PCB wastes in compliance with the commitments under the Stockholm and Basel
Conventions, technical and administrative capacity of GoI agencies in managing PCBs through destruction or
decontamination of 3,000 tons of PCB-containing equipment or PCB contaminated wastes.
23. Considering the large volume of PCB contaminated equipment within the power sector of Iraq, the Project will
evaluate various destruction and/or disposal scenarios both to maximize the impact of the quantity managed
with Project support and for further elimination of PCBs by Iraq. Options such as disposing PCB contaminated oil
and waste in a facility abroad or through in-country facilities such as cement kilns/ incinerators (to be developed)
will be explored. Each of these disposal scenarios will be carefully evaluated during the Project implementation
with due consideration to factors such as their feasibility, environmental impact (including GHG emissions, if any),
safety measures, and compliance with relevant regulations. Learning from the successful experience of Egypt POPs
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Project (P116230/GEF ID 3905), the Project will also explore the viability of procuring mobile de-chlorination unit
for treating in-service contaminated transformers and hiring a vendor to perform de-contamination activities and
providing on the job training to GoI team.
Component 3: Management of chemical pollution hotspots (US$4.85 million I3RF Grant)
24. Based on the recommendations of the chemical pollution hotspots analysis conducted by the World Bank and
MoEn5 and linkages with the objectives of the Project, this component proposes to support activities for the
management of these sites with financing from I3RF. In line with I3RF’s mandate, this component will focus on
the seven conflict affected governorates of Iraq and support the following activities:
(a) Detailed assessment and preparation of remediation plans for 3 to 5 priority chemical pollution
hotspots (US$2.00 million). The candidate sites will be selected based on the 76 hotspots identified
through the inventory and analysis referred above, and a detailed assessment will be conducted to
understand the nature and level of contamination/ pollution at the sites and the risks it poses to
communities. The detailed site assessments will involve site investigations, sampling surveys, assessment
of environmental, health and economic impacts in the influence area and development of management
and/or remediation plans based on risk-based criteria and future use of the site. The remediation plans
will be developed in close consultation and collaboration with local communities and stakeholders and
evaluate opportunities for private sector participation (if any) in implementing the remediation plans. To
strengthen synergies between components 1, 2 and 3 of the Project, efforts will be made to prioritize
hotspot sites contaminated with OPs or PCBs, so that detailed assessments can be conducted through this
activity, while management activities can be conducted through Component 2 of the Project. Depending
on the readiness of detailed assessments and time available for utilizing I3RF funds, this component will
also implement the remediation of priority sites.
Given that some of the hotspots are mixed with solid waste, this component will also support necessary
assessment/ analysis and activities for the improvement of the solid waste management scenario of Iraq.
(b) Development of standards and regulations (US$0.70 million) for the management of chemical pollution
hotspots in Iraq. This will involve (i) establishing a GIS based contaminated sites information system, (ii)
developing or strengthening GoI’s policy on contaminated sites management; (iii) preparing regulations
and standards to address chemical pollution/ contamination (soil, ground water and water quality
standards); (iv) developing of framework/ guidelines for the identification, assessment, risk assessment,
remediation and post remediation monitoring of chemical contaminated sites with inputs from
components 1 and 2; and (v) facilitating the development of a national program for the management of
chemical pollution hotspots with the necessary budget and resource allocation.
(c) Training and institutional development (US$2.15 million) for effective management of chemicals and
contaminated sites. This will involve supporting activities to evaluate various institutional models and
5World Bank. 2023. “Iraq Environmental Hotspots: Land Remediation for Livelihoods Restoration”.
https://documents.worldbank.org/en/publication/documents-
reports/documentdetail/099102723191012184/p1730490b252b40bd0a2b40df0215e54614
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developing detailed institutional structures for the management of chemicals and contaminated sites
management in Iraq. In addition, specific training will be provided to various stakeholder agencies on
chemical contamination, development of conceptual models, risk assessments and remediation plans/
programs. The capacity of MoEn for sampling and analysis of hazardous chemicals and soils will also be
supported through procurement of on-site monitoring and laboratory equipment, their calibration
requirements, accreditation, and maintenance protocols.
Component 4: Project Management, and Monitoring and Evaluation (US$0.73 million- US$0.58 million GEF
Grant and US$0.15 million I3RF Grant)
25. This component will support:
(a) the establishment and operation of the Project Management Unit (PMU) at the Ministry of Environment
and related activities conducted by MoA and MoElec. This will involve financing costs of PMU staff and
operating costs associated with day-to-day project management costs. (US$0.46 million- US$0.37 million
GEF and US$0.09 million I3RF Grant): and
(b) the preparation and implementation of monitoring and evaluation activities of the Project, collecting
evidence-based information and data and reporting in compliance to the World Bank and GEF guidelines
(GEF Environmental Policy, 2019 and updates on GEF Evaluation Policy). For Component 3 funded by I3RF,
the activities will be monitored and reported as per the specific reporting requirements of the donor
regularly and annually. (US$0.27 million- US$0.21 million GEF Grant and U$0.06 million I3RF Grant).
C. Project Beneficiaries
26. The Project activities are expected to directly benefit an estimated 7 million people (about 15.5 percent of Iraq’s
population) working and living around the sites/ facilities of Project intervention. The main benefits to these
people would be mitigation and avoidance of health and environmental impacts arising due to the exposure to
the hazardous chemicals present at the locations of Project interventions. Based on the overall distribution of
male female population in Iraq, it is expected that about 49 percent of the Project beneficiary will be women.
27. In addition, about 19.3 million people are expected to benefit indirectly due to improved living conditions in
the towns and cities, water and soil quality, livelihoods, and agriculture productivity around the Project sites.
It is however important to note that these estimates of direct and indirect beneficiaries are indicative, as the exact
locations of Project interventions will be finalized during the Project implementation based on detailed
assessments and risk-based prioritization. Accordingly, the actual beneficiaries of the project, will be updated
during the implementation phase of the project.
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D. Results Chain
28. The theory of change for the Project as presented in the figure below, envisages mitigation of significant
environment and health risks to the population by safely managing / disposing high-risk priority OPs and PCBs
in Iraq. In addition, the capacity building provided through the Project is expected to facilitate reduction of long-
term health and environmental risk to the people (figure below), through follow-on interventions by the GoI. The
critical assumptions underlying the results chain include: (i) key stakeholders in hazardous chemicals management
closely collaborate in the implementation of the Project and beyond; (ii) the security situation in the country will
allows for the participation of competent and experienced international consultants and contractors in the
implementation of Project activities; and (iii) GoI pursues the implementation of policy, institutional and
regulatory tools developed by the Project and complies to the commitments made under Stockholm Convention.
Theory of Change Problem Statement: POPs and Hazardous Waste are posing severe health and environmental risks in Iraq
OUTCOMES
ACTIVITIES OUTPUTS Short-term outcomes Medium-term outcomes Long-term Impact
Updating NIP for Updated NIP POPs including new POPs
Improve management of POPs &
POPs
hazardous chemicals
Policy instruments, technical guidelines Action plan for
Policy, regulatory for OPs and PCBs and operational Policy and
POPs management
and institutional system for their tracking institutional
and prioritization of
strengthening actions initiated
national strategic
Training, laboratory strengthening for objectives
POPs and Hazardous Chemicals
Capacity Building
Management and Disposal of
Management and Reduced health
Containment and disposal /destruction Prevention, Sustainable
Disposal of OPs in & environmental
of OPs Reduction and Management of
agriculture sector risks from POPs
POPs
v Disposal of POPs POPs hazardous and HW in Iraq
hazardous waste waste
Management and Treatment and disposal of PCBs
disposal of PCBs in
power sector
Mgmnt. of Chemical
Detailed
pollution hotspots
Remediation Plan for Priority Sites
assessment of
priority hotspots Enabling framework Implementation of
for National National Program
Regulations and Standards for
Development of Program on for Contaminated
contaminated sites management
standards and contaminated sites Sites
regulations
Training and Laboratory Strengthening
Capacity Building for hazardous chemicals
for hotspots
E. Rationale for Bank Involvement and Role of Partners
29. Pollution management Projects, especially those involving hazardous chemicals such as OPs and PCBs, are
technically complex and countries have limited capacity to implement. Bank’s support to GoI through GEF and
I3RF financing will help demonstrate the implementation of these complex technologies and build capacity of GoI
in managing hazardous chemicals. This will facilitate scaling up the program to address significant environmental
challenges of Iraq.
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30. In terms of experience, the Bank has supported several pollution management projects including projects
involving PCBs and OPs financed by GEF both in MENA region and in other countries. Some of the successful
projects in MENA include Egypt Sustainable POPs Management Project (P116230), Lebanon PCB Management in
Power Sector Project (P122540) and PCB management project in Tunisia (P100478). In addition, Bank has
implemented/ is implementing projects across other regions including Viet Nam (P099460), China (P082993),
Moldova (P090037), Nigeria (P113173). This strong portfolio of experience, sector knowledge and relationship
with government institutions in Iraq, helps the Bank to better design the Project and support implementation.
31. The Project closely co-ordinates with development partners such as UNEP and United Nations Development
Program (UNDP) working in the sector/ country and leverages funding from programs such as GEF and I3RF to
support GoI on this important pollution management project. As highlighted earlier, the Project builds on the
NIP prepared by UNEP and leverages the analysis jointly conducted by MoEn and the Bank on environmental
hotspots.
F. Lessons Learned and Reflected in the Project Design
32. The design of the Project has benefited from the experience of supporting similar projects by the Bank. Learning
from previous Bank projects, the Project will explore the feasibility of implementing two innovations successfully
demonstrated in Egypt and Lebanon. The first of them is to assess the feasibility of co-processing of OPs in cement
kilns, which will save the costs of sending them abroad for incineration and ensure long term management of OPs
beyond the Project life. Similarly for PCBs, the Project will assess the technical viability of de-chlorination of PCB
contaminated oil in online transformers with appropriate technologies. In addition, the Project will adopt ‘learning
by doing approach’ to build the technical capacity of MoEn and will facilitate collaboration with Egyptian and
Lebanese agencies (who successfully implemented POPs and PCBs projects). This regional collaboration between
government agencies will ensure more effective capacity building than conventional technical training programs.
III. IMPLEMENTATION ARRANGEMENTS
A. Institutional and Implementation Arrangements
33. MoEn will be responsible for the overall implementation of the Project in terms of, (i) managing the Project in
line with the overall design and agreed procurement and financial management arrangements; (ii) ensuring the
implementation of Environmental and Social Framework (ESF) requirements including the Environmental and
Social Commitment Plan (ESCP) of the Project; (iii) monitoring the results towards the achievement of agreed
outcomes; and (iv) complying with reporting requirements of both Grant Agreements (GA) for GEF and I3RF.
34. For the purposes of implementing the Project, MoEn will establish a PMU comprising of qualified and
experienced technical, financial, procurement, environment, and social specialists. The PMU will be responsible
for overall planning, implementation and management of the Project activities and will supervise the
implementation of activities by the consultants, contractors, and other agencies. The PMU will also coordinate
with other stakeholder ministries such as MoA, MoElec, the KRI in implementing the Project activities.
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35. To complement its efforts in Project implementation, the MoEn will seek the support of UNDP or any other UN
Agency to implement part of the Project activities. It is envisaged that, the concerned agency (UNDP or any other
UN agency) will support MoEn in implementing all activities under components 1, 2 and 3 of the Project. MoEn
will sign an agreement with the selected UN agency using the Bank’s standard output agreement to deliver these
activities. MoEn has initiated discussions with UNDP for this purpose, however a flexible approach is being
adopted, so that the government can sign the agreement with any other UN Agency subject to prior approval of
the Bank. MoEn and the PMU will supervise the activities implemented by the UN Agency in close coordination
with the GoI, relevant ministries and all Project stakeholders.
36. To facilitate coordination and active participation of various GoI agencies, relevant ministries, and other
stakeholders for the overall implementation of the Project, MoEn will establish a “Project Steering Committee
(PSC).” The PSC will be established in close consultation with GoI ministries, departments, agencies, and other
stakeholders relevant to the Project and will include MoEn, MoA, MoElec, Ministry of Oil, Ministry of Industry and
Minerals, Ministry of Planning, Ministry of Science and Technology, Ministry of Finance and other stakeholders as
needed. The PSC will comprise at least 30 percent of qualified women to ensure that the different needs and risk
factors of women are duly considered and mainstreamed in the Project.
37. The main objective of the PSC will be to (i) review the Project progress and provide strategic guidance in Project
implementation; (ii) facilitate coordination/ collaboration between PMU and other parties; (iii) facilitate
resolution of implementation challenges including any statutory and administrative approvals that may be
required for the Project; and (iv) ensure synergies between Project activities, other initiatives of the government
and other development partners. The PSC will also ensure appropriate participation of relevant officials of MoEn
in the implementation of the Project, to facilitate the transfer of knowledge from the PMU, UN Agency and other
technical experts involved in the Project. Such participation will also help with capacity building of ministries in
ensuring sustainability of the Project interventions and their scale up in future. The Project Operations Manual
(POM) prepared for the Project will also guide the overall implementation of the Project. Further details on project
implementation arrangements are elaborated in Annex 1.
38. In addition, a Third-Party Monitoring Agency (TPMA) will be engaged by the Bank to monitor Project activities .
The TPMA will report on the progress of all activities, outputs, status of achieving the results and the fiduciary and
ESF implementation. The TPMA will share its monitoring report with the World Bank and the findings of the report
will be discussed with MoEn and corrective actions with timelines will be agreed. MoEn accordingly will submit a
report on the corrective actions taken to address issues identified by the TPMA to the World Bank.
B. Results Monitoring and Evaluation Arrangements
39. MoEn will be responsible for results monitoring and reporting in line with the agreed Results Framework of the
Project and the requirements of the World Bank, GEF and I3RF. In doing so, the ministry will collaborate with
stakeholder ministries and the UN Agency supporting components 1,2 and 3, and collect relevant data/
information based on the approach and methodology agreed in the POM for the Project. A Monitoring and
Evaluation (M&E) expert will be recruited for this purpose who will be responsible for this function and to ensure
timely and efficient implementation of the M&E plan of the Project.
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C. Sustainability
40. The overall sustainability of the Project is demonstrated by GoI through its commitment to the elimination of
POPs by (i) ratifying the Stockholm Convention; (ii) preparing the NIP for initial POPs; (ii) seeking GEF and World
Bank’s support in designing and implementation of the current Project and (iv) committing to provide US$25
million in kind contribution and additional US$64 million for programs and activities that support efficient
operation and maintenance of various Project interventions. Sustainability of Project outputs and outcomes
beyond Project life is thus expected to be high.
41. Sustainability elements have also been mainstreamed in the Project design by adopting an integrated approach
in designing the components. The overarching objective of the Project is to support the GoI in meeting its legal
obligations under the Stockholm Convention by identifying all types of POPs and demonstrating implementation
of environmentally sound technologies for their management. In addition, the design of the Project reflects the
following sustainability elements.
▪ Institutional sustainability. This is evinced through strong buy-in from stakeholders and their commitment to
mobilize seven times the GEF grant to ensure sustainability and scaling up Project interventions. The Project
further supports institutional sustainability by (i) strengthening the institutional structure, (ii) strengthening
policies and regulations, (iii) developing strategies, methodological tools, and technical skills, (iii) providing
training and capacity building of institutions, and (iv) enhancing public awareness for POPs management.
▪ Environmental and social sustainability. By supporting the disposal/ management of OPs and PCBs, the
Project contributes to significant environmental and social benefits such as reduced risk of health hazards to
communities (including women and children), improved soil quality, water quality, etc. This contributes to
environmental and social sustainability by enhancing agriculture productivity, livelihoods, and possible return
of internally displaced people in the areas of Project interventions.
▪ Economic sustainability. Based on financial and economic analysis of different alternatives to eliminate POPs,
the Project will explore the feasibility of developing in-country treatment/ disposal options, such as co-
processing of OPs and PCB oils in cement plants, procurement of mobile PCB di-chlorination units. This will
enable development of local infrastructure for the management of POPs in Iraq, thereby building capacity of
the country for the long-term management of POPs and economic sustainability.
IV. PROJECT APPRAISAL SUMMARY
A. Technical, Economic and Financial Analysis (if applicable)
(i) Technical Analysis
42. The Project is designed to demonstrate environmentally sound management of hazardous chemicals (POPs and
other chemicals) and build capacity for managing these substances over a longer term. Accordingly, the
components are designed based on strategies and action plans recommended by the NIP for POPs and assessment
conducted by World Bank together with MoEn on environmental hotspots. In addition, further analysis of OPs and
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PCBs scenario in Iraq was carried out during the Project preparation, to understand (i) POPs monitoring,
enforcement and management practices by MoEn (ii) current practices of OPs management by MoA, (iii) current
system of monitoring, assessing and management of PCB contamination in transformers and other equipment by
MoElec, (iv) policy, regulatory and institutional mechanisms for POPs management in KRI, (v) capacity of all
stakeholder ministries and agencies and (vi) overall institutional co-ordination mechanism for POPs and chemicals
management in Iraq. This analysis and due diligence indicated the following.
▪ Need for comprehensive inventory of all POPs (OPs, PCBs, UPOPs and IPOPs), that could not be conducted
during the preparation of current NIP and its updating.
▪ Possibility of finding new stockpiles of OPs or PCBs due to limited sampling and assessment done during the
preparation of the NIP.
▪ Limited laboratory capacity of all agencies in testing and analysis of POPs and hazardous chemicals.
▪ Significant chemical contamination due to the series of conflicts and the need for an integrated approach for
managing POPs and other hazardous chemicals.
▪ Presence of large quantities of POPs and widespread chemical contamination across the country, emphasizing
the need for exploring innovative treatment and disposal technologies that are economical and sustainable.
43. The Project incorporates findings of the above assessment and adopts an integrated and flexible approach both
in the design of the components and technologies that can be adopted for managing/disposing the targeted 4000
tons of POPs. More specifically, the Project includes the following measures.
▪ Designing sub-component 1.1 covering all types of POPs (OPs, PCBs, UPOPs and IPOPs) involving detailed
inventory, sampling and assessment and comprehensive update of NIP along with appropriate cost allocation.
▪ Designing component 2 to identify high risk OPs and PCBs stockpiles to be destructed/ disposed during project
implementation through detailed assessment and risk analysis of potential sites, rather than pre-identifying
sites during preparation.
▪ Leveraging US$5 million I3RF grant for the management of chemical contaminated sites (component 3), to
integrate enabling policies, regulations and capacity building activities for contaminated sites and POPs.
▪ Including procurement of laboratory and / or field equipment through sub-components 1.3 and component 3
▪ Including studies to assess the feasibility of co-processing OPs, PCB oils in cement plants (sub-component 1.1)
and procurement of mobile dichlorination unit for the decontamination of online transformers from PCBs
(sub-component 2.2).
These features of the Project are expected to address the issue of POPs and hazardous chemicals management in
Iraq in an integrated manner and enable successful implementation of the Project and sustainable POPs
management beyond the Project.
(ii) Economic Analysis
44. The Project contributes to local and global public goods by supporting intangibles (preparing NIP, capacity
building, etc.) and tangible investments to dispose OPs and POPs to reduce the risks to health and environment.
These interventions will benefit (i) workers handling these substances; (ii) local communities including women
who may be exposed through contact or use of contaminated water or food or inhalation; and (iii) the global
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environment from reduced exposure from the release of dioxins and furans into the atmosphere. Accordingly, a
three-pronged economic analysis was performed where the project efficiency is gauged by conducting a benefit
cost analysis.
45. Quantitative Analysis. The economic analysis was conducted (i) considering the more quantifiable health benefits
associated with the safe disposal of the POPs and PCBs treatment, and (ii) benchmarking disposal costs from
similar projects supported by the Bank. The Project investments with a discounted rate of 6 percent, show a robust
economic internal rate of return of 23 percent over 25 years. A sensitivity and scenario analysis was also carried
out to get a more comprehensive understanding of the possible outcomes of the project. The economic analysis
carried out for the project is further elaborated in Annex 1.
Paris Alignment and Climate Change
46. The project contributes to the objectives of Iraq’s NDCs (2021)6 related to the health sector on preventing climate
and pollution induced diseases. It also aligns with Iraq’s Country Climate and Development Report7 for pollution
management and National Development Plan (2024-28)8 objectives on waste management.
47. Assessment and reduction of adaptation risks. Polluted sites and contaminated land can be impacted by climate
change, with significant negative impacts both for the health of ecosystems and human population. While
frequent and intense storms increase the likelihood of flooding of contaminated land and increased run-off from
contaminated stockpiles, frequent and intense drought can affect water-intensive remedies and site stability.
Similarly, flooding and drought can result in unregulated release of chemicals through surface soils, ground water,
surface and/or coastal waters, which can complicate cleanup efforts or threaten remediated sites, and higher
temperatures can increase the availability of contaminants, affect the transport of persistent organic pollutants,
and increase the rate at which ecosystems and organisms absorb or process contaminants. Changes in
temperature can also affect the effectiveness of some remediation systems. Wildfires can spread contaminants
and damage site infrastructure. The destruction of organic matter by fire can affect the behavior of metals in the
soil, which can alter mobility and lead to significant quantities of metal leaching into groundwater. The project
has incorporated actions to reduce these risks to an acceptable level through incorporation of standards for
harmonized national regulatory and administrative framework for PCBs and PCB wastes in compliance to the
commitments under Stockholm and Basel conventions (Component 2).
48. Assessment and reduction of mitigations risks. The Project is Paris Aligned and integrates climate change
considerations in the design and implementation of its components. More specifically, the selection of disposal/
destruction technologies for OPs and PCBs will consider GHG emission potential and the most feasible option will
be selected. Further, the Project will support adopting cleaner processes and recycling initiatives for the
management of POPs and hazardous chemicals, thereby contributing to reduction in GHG emissions. This
approach not only mitigates immediate impacts on climate but also contributes to long-term climate resilience
and reducing risks to communities vulnerable to climate risks. These measures also reduces GHG emissions to a
low level.
6 https://ndcpartnership.org/country/irq
7 https://documents1.worldbank.org/curated/en/099005012092241290/pdf/P1776390cfceae0d908ff8073b7e041bea6.pdf
8 https://www.undp.org/iraq/publications/iraq-national-development-plan-2024-2028
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Gender
49. Efforts to ensure sound management of chemicals, including POPs, will have many gender dimensions. The most
Important of them include vulnerability of women to health impacts from (i) exposure to hazardous chemicals
based on type, level, and frequency of exposure, and (ii) bioaccumulation of chemicals to pass from mother to
baby from utero and breast milk. Project specific gender analysis was conducted to better understand the gender
situation in Iraq and a Gender Action Plan (GAP) is developed by MoEn in line with the GEF Policy on Gender
Equality requirements (2018), WBG Strategy on Gender equality, poverty reduction, and inclusive growth (2016-
2023)9, and Sustainable Development Goals (SDGs)10.
50. Considering the gender sensitivities associated with chemical contamination and the findings of the Stockholm
Convention11, various other organizations12 and GAP, the Project will support implementation of actions that (i)
ensure integration of gender dimensions in the policies and regulations to be developed for POPs and hazardous
chemicals, (ii) facilitate women empowerment by ensuring equitable representation of women (at least 30
percent) in key decision making bodies such as the Federal Coordination Committee for the implementation of
NIP and the Project Steering Committee (iii) ensure integration of risk reduction measures in the design and
implementation of Project activities to avoid the adverse effects of chemicals on the health of men and women
through focused consultations with different groups, (iv) collect and analyze gender disaggregated data in
identifying direct beneficiaries of the Project and also in all studies/ activities supported by the Project, so that
Project interventions are gender informed and (v) promote equal opportunities to women by ensuring
employment of women in the PMU and other agencies likely to work on the Project.
Citizen Engagement
51. Citizens Engagement activities and engagement with all stakeholders will be conducted all through Project
implementation. The Project conducted extensive consultations with various stakeholders including citizens
representatives during Project preparation. This approach will be continued during implementation and the
Project will adopt a multi-stakeholder consultation process to ensure citizen engagement, inclusion, and
ownership among beneficiaries. This will entail meaningful consultation and feedback mechanisms and focus
group consultations and participatory mechanisms. A Grievance Mechanism (GM) will be set up for the Project in
line with the ESF requirements of the Bank. The GM will integrate local channels of communication/ complaint
mechanism, to ensure receipt of continued inputs and concerns from communities on Project activities. The GM
will also include referral pathways in the event of any sexual exploitation and abuse and sexual harassment
(SEA/SH) complaints related to the Project and will adopt principles of confidentiality and anonymity.
9 With a particular emphasis on what it concerns gender equality in fragile and conflict-affected situations
10 Particularly SDG5 (gender equality), SDG3 (good health and well-being), SDG6 (clean water and sanitation), SDG8 (decent work and economic growth), and SDG12
(responsible consumption and production), SDG13 (climate action), and SDG15 (life on land).
11 UNEP/POPS/COP.6/INF/33 (2013), “Human Exposure to POPS Across the Globe: POPS Levels and Human Health Implications – Results of the WHO/UNEP Human
Milk Survey” https://chm.pops.int/Portals/0/download.aspx?d=UNEP-POPS-PAWA-CASES-HumanExposureToPOPsAcrossTheGlobe.En.pdf
12 Women in Europe for a Common Future, 2016 “Women and Chemicals: The impact of hazardous chemicals on women – A thought starter based on an experts’
workshop”. https://www.wecf.org/wp-content/uploads/2018/12/WomenAndChemicals_PublicationIWD2016.pdf
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Private Sector Engagement
52. The Project seeks to engage with the private sector, to ensure its involvement in improving the management
of POPs. This is important, as private sector plays a significant role in Iraq in the (i) import and production of
pesticides and (ii) manufacture and maintenance of transformers and other equipment in the power sector.
Considering this, the Project will hold consultations with private sector in the development of NIP and policies
that facilitate involvement of private sector in the management of POPs. In addition, including private sector/
industry representatives in the Federal Coordination Committee for POPs will also be explored and inputs will be
sought on various activities being planned by the GoI for POPs management in Iraq. Through these engagements,
the Project aims to improve industry practices in (i) pesticides production, storge and distribution and (ii)
manufacture and management of transformers and prevent issues of pollution due to unsafe practices.
53. The Project will collaborate with the private sector and explore the feasibility of in-country destruction and
disposal of POPs. To facilitate this, the Project will share information on environmentally sound and economically
feasible alternatives/alternative technologies with the private sector and engage in a dialogue to implement them
in Iraq. These include assessing the viability of (i) modifying the manufacturing process and investments to enable
co-processing of OPs and PCBs in the cement kilns, (ii) analyzing the issues and enabling reuse of di-chlorinated
PCB oils. Successful implementation of either or both these initiatives will ensure long-term sustainability of the
Project interventions and mobilize significant private sector financing.
B. Fiduciary
(i) Financial Management
54. The Financial Management (FM) assessment conducted for MoEn found that the FM risk, as a component of
the fiduciary risk, is ‘high’ and is expected to be ‘moderate’ after the implementation of mitigation measures.
The key FM risks are (i) the complex nature of Project activities requiring specialized contractors/consultants for
Project implementation which would make it challenging to have proper oversight on utilization of Project funds
(ii) limited capacity of MoEn to meet Project’s financial management requirements and (iii) overall weakness and
shortcomings in the control environment including banking system. To address these risks, the proposed
mitigating measures are: (i) submission of detailed financial reporting on a quarterly basis from MoEn to the Bank
as per the content and format of the financial reports agreed (ii) conducting yearly external financial audit of the
Project; (iii) engaging UNDP or other UN agency to support management and implementation of part of the Project
activities and (iv) including a computerized accounting system to record the transactions and payments made and
report to the Bank on a quarterly basis. With these proposed mitigating measures, the MoEn will have the FM
requirements and will have an acceptable FM system, and the residual FM risk rating would be Moderate. A more
detailed FM assessment and arrangements are provided in Annex 1.
55. The MoEn will engage UNDP or other UN agency to support the management and implementation of part of
the Project activities. These activities will be mainly related to components 1,2 and 3 of the project. MoEn will
sign an agreement with UNDP or UN Agency following WBG’s standard form of output agreement and this
agreement will include specific detailed financial reporting by the agency comprising detailed breakdown of
expenditures by component and by activity. The format and content of the financial reports will be agreed upon
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with the selected UN Agency and will be included in the output agreement. The financial reports will be required
on a quarterly basis to be submitted 45 days after the end of each quarter. The activities to be implemented by
the selected UN Agency will be validated by the Third-Party Monitoring Agency (TPMA) and will be verified as per
the agreed terms of references.
(ii) Procurement
56. Applicable Procurement Regulation. Procurement activities will be conducted in accordance with the: “The World
Bank Procurement Regulations for IPF Borrowers - Procurement in Investment Project Financing, Goods, Works,
Non-Consulting and Consulting Services” 5th edition, dated September 2023. The Borrower will also ensure that
the Project is conducted in accordance with the provisions of the “Guidelines on Preventing and Combating Fraud
and Corruption in Projects Financed by IBRD Loans and IDA Credits and Grants,” dated October 15, 2006, and
revised in January 2011 and as of July 1, 2016 (Anti‐Corruption Guidelines). As required by the World Bank’s
Procurement Framework, a Project Procurement Strategy for Development (PPSD) including a comprehensive, fit-
for-purpose Procurement Plan for the first 18 months of the Project has been prepared. The Project will use
Systematic Tracking of Exchanges in Procurement (STEP) to plan, record, and track procurement transactions.
57. Procurement implementation arrangements. The MoEn will be responsible for overall Project procurement
activities through the PMU that will be established to include, among others, a Project coordinator (technical),
procurement, and financial officer. The MoEn has limited experience in WB-financed projects and procurement
regulations, with little experience in procurement planning, monitoring, and contract management; therefore,
the PMU will need to be supported by an experienced procurement specialist to provide support during the
procurement cycle, especially while contracting the UNDP or other UN Agency and to provide support in
supervising the contracts with the UN Agency. As per updated Procurement Procedure for IPF 2024, the Contract
with UN agency, regardless of value, will be subject to Bank’s prior review. Draft POM with detailed project
procurement arrangements and applicable thresholds has been developed by MoEn.
58. Key procurements under the Project. The Project activities under components 1,2 and 3 will be providing
technical assistance, knowledge management, institutional strengthening and capacity building, and advisory
services, as well as procuring essential facilities, and equipment to support the technical assistance. The Project
will also finance works to manage and dispose of hazardous waste. The MoEn will engage UNDP or other UN
Agency to support the management and implementation of Project activities and sign an output agreement with
the agency. Component 4 will finance a few simple and small-value procurement of goods and consultants’
services for project management, M&E, and financial audit.
59. Procurement risks of the Project are identified as “ High” due to : (i) Limited experience of MoEn in working on
Bank financed projects; (ii) limited capacity of the implementing agency (MoEn) in World Bank procurement policy
and procedures, procurement planning and management contracts, (iii) the volatile political economy; (v) high
perception of fraud and corruption in a high risk and weak control environment, (iv) complexity of coordination
with other stakeholders such as ministries and public institutions; and (v) possible delays in implementation due
to the occasional escalation in the security situation of the country, long decision-making process, and delay in
registration of contracts in Ministry of Planning (MoP) national investment budget, and (vi) restricted
travel/mobility of Bank staff and difficulty to supervise Project sites; poor internet service to use Bank systems,
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e.g., Client Connection and STEP. More details on procurement risks and mitigation measures are outlined in
Annex 1.
C. Legal Operational Policies
@#&OPS~Doctype~OPS^dynamics@padlegalpolicy#doctemplate
Legal Operational Policies Triggered?
Projects on International Waterways OP 7.50 No
Projects in Disputed Area OP 7.60 No
D. Environmental and Social
60. The Environment Risk Rating is considered High. The overall outcome of the Project will be positive, as the Project
supports environmentally sound management of POPs and hazardous chemicals in Iraq. However, POPs are highly
toxic and exposure to these substances can happen through food, environment, or accidents. Some or many of
the impacts will cause significant, long-term, irreversible Environment, Health, and Safety (EHS) risks and adverse
impacts on the population and environment. The exposure could happen during the implementation of Project
activities such as handling (collection, packaging, storage) and disposal of POPs, leading to EHS/ Occupational
Health and Safety risks to the people involved in the operations and to the neighboring communities. Some of the
impacts cannot be mitigated or can be addressed with special interventions requiring complex and/or unproven
mitigation and/or compensation measures or techniques. In addition, the Project activities could also lead to
contamination of soil from spills of OPs/ PCBs and hazardous chemicals during sampling, temporary storage, and
treatment/ disposal stage. Other factors considered in this risk rating are that POPs can be transported by wind
and water, most POPs generated in one country can and do affect people and wildlife far from where they are
used and released. The other criteria are the fragility of Iraqi environment which already suffered from high level
of contamination at all fields, and the Project is the first high risk ESF project with MoEn which will pose a challenge
to manage. Therefore, the environment risk has been rated as ‘High’.
61. The Social Risk Rating is considered Moderate. Although the true extent of POPs and hazardous waste
contaminated land in Iraq is yet to be confirmed, a significant area of land is polluted by hydrocarbons and other
chemicals. This situation leads to health and safety impacts on local communities and potentially placing an
additional burden on the already strained social welfare and human health. In terms of impacts, based on the
available information, implementation of various activities through the Project are not expected to involve
acquisition of private land and cause direct adverse social impacts. However, occupational health and safety
impacts to the workers and local communities are likely during implementation. Also, many of the storage sites
of OPs are in the warehouses/ store yards and isolated industrial sites. Hence, no loss of agriculture revenue and
livelihood impacts are anticipated.
62. The Project will undertake proper measures to reduce environmental and social risks and impacts through
environmental and social mitigation measures defined in various environmental and social instruments of the
Project such as Environmental and Social Management Framework, Stakeholder Engagement Plan, SEA/SH
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prevention and response plan, and Labor Management Plan. These instruments have been reviewed by the Bank
and disclosed by the World Bank and MoEn on November 13, 2023. In line with World Bank’s Environmental and
Social Framework requirements and complying to environmental and social standards and Environmental and
Social Commitment Plan agreed for the Project, appropriate instruments will be prepared during the
implementation phase, for each of the sites prioritized where OPs and PCBs containment and management will
be conducted. These instruments will evaluate all environmental and social risks including labor influx, child labor,
gender-based aspects, discrimination, and impacts on local communities and appropriate mitigation measures
will be identified and implemented. Engagement of stakeholders in all phases of the Project and periodic
monitoring according to the World Bank Environmental and Social Framework will also be ensured. Active efforts
will be made to seek stakeholders’ feedback on the design and implementation of the Project activities. The modes
and frequency of engagement is identified in the Stakeholder Engagement Plan. Overall Project level and sub-
project level functional GM will also be established and communicated during the stakeholder consultations. The
Project GM is the same as the MoEn’s GM system. The GM system will include multi-level arrangements for
registering and addressing grievances and complaints from program-affected people, building on the existing
functional system of the MoEn which is receiving and addressing complaints mainly via the nation-wide system.
The existing GM was assessed against good international practice including Environmental and Social Standard 10
and recommended improvements for accessibility and effectiveness, standard operating procedures; expanded
outreach; community-based dispute resolution mechanisms; referral protocols for complaints related to labor and
working conditions and SEA/SH.
V. GRIEVANCE REDRESS SERVICES
63. Grievance Redress. Communities and individuals who believe that they are adversely affected by a project
supported by the World Bank may submit complaints to existing project-level grievance mechanisms or the
Bank’s Grievance Redress Service (GRS). The GRS ensures that complaints received are promptly reviewed to
address project-related concerns. Project affected communities and individuals may submit their complaint to
the Bank’s independent Accountability Mechanism (AM). The AM houses the Inspection Panel, which
determines whether harm occurred, or could occur, as a result of Bank non-compliance with its policies and
procedures, and the Dispute Resolution Service, which provides communities and borrowers with the
opportunity to address complaints through dispute resolution. Complaints may be submitted to the AM at any
time after concerns have been brought directly to the attention of Bank Management and after Management
has been given an opportunity to respond. For information on how to submit complaints to the Bank’s
Grievance Redress Service (GRS), visit http://www.worldbank.org/GRS. For information on how to submit
complaints to the Bank’s Accountability Mechanism, visit https://accountability.worldbank.org.
VI. KEY RISKS
64. The overall residual risk to achieving the PDO is rated ‘Substantial.’
65. Political and governance (High). Considering the political instability in the country and geopolitical risks, the
political and governance risk is rated as ‘high.’ These risks will impact the ability of implementing the Project by
MoEn and other participating ministries. Finalization of NIP and other Policy/ regulatory measures envisaged by
the Project will also be impacted by the governance risks in the country. To mitigate these risks, the task team will
(i) monitor the developments in GoI that could impact the Project, (ii) ensure close co-ordination between the
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Bank and GoI to appropriately resolve bottlenecks and pending issues, and (iii) adapt Project activities to changing
governance priorities of GoI, but within the overall framework of achieving the PDO.
66. Macroeconomics (Moderate). Iraq is facing macroeconomic risks related to external shocks including the volatility
in oil prices and the high financing needs for reconstruction and investment. Since the Project is fully grant
financed, these dynamics are unlikely to create bottlenecks in financing the Project. However, Macroeconomic
risks are likely to affect the counterpart financing envisaged for sustaining the activities beyond the Project. The
Project has tried to mitigate these risks by identifying these commitments through in-kind contribution of existing
staff of participating ministries, ongoing programs of GoI already planned through the national budget. In addition,
other mitigation measures will be designed during the implementation phase of the Project, as appropriate.
Macroeconomic risks, hence, are rated ‘moderate.’
67. Sector strategies and Policies (Moderate). The regulatory framework and technical capacity of institutions in Iraq
to manage hazardous and chemical substances needs strengthening. However, the Project has been developed in
response to GoI’s commitments under the Stockholm Convention and number of initiatives by MoEn on chemical
pollution. This indicates a reasonably good level sectoral framework and necessary institutional support for the
Project. In addition, the Project will support strengthening policy and regulatory framework for hazardous waste
and chemicals management. Considering this, the risks on sector strategies and policies is rated as ‘Moderate.’
68. Technical design (Substantial). The Project activities, especially treatment and disposal of POPs envisaged under
component 2 are technically complex. However, the technologies are well established, and Bank has successfully
implemented these technologies in similar countries (Egypt and Lebanon) in the region. Given the security
scenario in Iraq, the participation of international consultants and contractors may be limited, which could hinder
Project implementation, as envisaged. The risk is proposed to be mitigated by encouraging the collaboration of
local agencies with international consultants, deployment of qualified and experienced local professionals (where
feasible), additional technical support by the Bank team and exploring the feasibility of in-country disposal of
POPs. Accordingly, the technical design risk of the Project has been rated as ‘substantial.’
69. Institutional capacity for implementation and sustainability (Substantial). The ‘Chemicals and Contaminated
Sites Assessments Division’ of MoEn has developed good capacity with regard to chemicals and hazardous waste
management through support from World Bank and various UN agencies. However, MoEn has implemented small
technical assistance projects supported by the World Bank and not any major investment projects. Hence, they
have limited knowledge of the Bank’s fiduciary and ESF requirements. On the other hand, MoA and MoElec have
been working with the World Bank on various sectoral projects. Considering this, the institutional capacity risk for
implementation and sustainability of the Project is rated ‘substantial.’ This risk is proposed to be mitigated through
hiring UNDP or other UN agency to support implementation of some parts of the project (components 1,2 and 3),
providing ‘handholding’ support to GoI institutions through Bank team and consultants hired for the Project and
following ‘learning by doing approach’ for all Project activities.
70. Fiduciary (High). Fiduciary risk is rated ‘High,’ as elaborated in the fiduciary section of appraisal summary above.
71. Environmental and Social Risks (High). The environmental risk is rated “high” and social risk is rated “moderate,”
as elaborated in the appraisal summary section above.
72. Stakeholders (Substantial). Given the range of stakeholders both within the Government and with local
communities, the stakeholders’ risk is rated as ‘substantial.’ To address this risk, the Project will support a pro -
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active and inclusive stakeholder and citizen engagement process and has developed an inclusive communication
and a stakeholder engagement plan with an objective to maintain close consultation with different public and
private stakeholders and civil society in implementing the Project.
73. Other - Conflict and Violence (High). The risk due to ‘Conflict and Violence’ is rated as high due to volatile security
situation in Iraq. In addition, Bank team’s access to Iraq remains limited due to security consideration and political
instability. This makes the Project implementation difficult. To mitigate this situation, the Bank team will adopt
flexible approaches such as (i) virtual missions; (ii) reverse implementation missions in Jordan or Beirut; (iii)
deployment of alternate monitoring arrangements such as hiring Third Party Monitoring Agency and local experts;
(iv) consider access restrictions and quickly adapt to changing circumstances on the ground. The team will also
rely on WBG’s security assessments and FCV monitoring systems and plan implementation support missions
accordingly.
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VII. RESULTS FRAMEWORK AND MONITORING
@#&OPS~Doctype~OPS^dynamics@padannexresultframework#doctemplate
PDO Indicators by PDO Outcomes
Baseline Closing Period
Improve the management and safe disposal of POPs and Hazardous Chemicals in Iraq
OPs and PCBs destroyed or disposed or contained (Metric ton)
May/2024 Dec/2031
0 4,000
Policies and regulations for the management of PoPs, Hazardous Chemicals and pollution hotspots developed (Number)
May/2024 Dec/2031
0 4
Share of POPs monitored through the management information system established through the project (Percentage)
May/2024 Dec/2031
0 50
Direct Project Beneficiaries (Number)
May/2024 Dec/2031
0 7,000,000
Intermediate Indicators by Components
Baseline Closing Period
Improving the management framework for POPs and hazardous chemicals
Updated National Implementation Plan for POPs prepared (Yes/No)
May/2024 Dec/2031
No Yes
Capacity of participating agencies in sampling and analyzing the number of chemicals including OPs, PCBs (Number)
May/2024 Dec/2031
0 15
➢Analytical capacity of Ministry of Environment in sampling and analyzing the number of hazardous chemicals (Number)
0 6
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National Inventory of POPs (OPs and PCBs) completed and system for their tracking and management operational (Yes/No)
May/2024 Dec/2031
No Yes
Staff trained in the inventory, assessment and management of chemical contaminated sites (hotspots) and POPs (Number)
May/2024 Dec/2031
0 240
➢Staff trained in detailed assessment, management and remediation of hazardous chemical contaminated sites (hotspots) (Number)
0 60
Management and disposal of high-risk priority stockpiles of POPs in agriculture and power sectors
OPs contained and/ or dispsosed (Metric ton)
May/2024 Dec/2030
0 1,000
PCB contaminated equipment and waste managed and / or destroyed (Metric ton)
May/2024 Dec/2030
0 3,000
Management of chemical pollution hotspots
Detailed assessments conducted and remediation plans prepared for chemical contaminated sites (hotspots) (Number)
May/2024 Dec/2025
0 3
Project management, Monitoring and Evaluation
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Monitoring & Evaluation Plan: PDO Indicators by PDO Outcomes
Improve the management and safe disposal of POPs and Hazardous Chemicals in Iraq
OPs and PCBs waste destroyed or disposed or contained (Metric ton)
This indicator measures activities implemented by the project to improve management and disposal of high risk stockpiles
Description
of POPs (1000 tons of Obsolete Pesticides and 3000 tons of PCBs).
Frequency Half-yearly
Data source Project Managmeent Unit (PMU) and Project Implementation Entity (PIE)
Data will be collected and analysed through (i) inventory of OPs and PCBs developed under component 1, (ii) detailed
Methodology for Data
assessment and treatment/destruction/ disposal plan developed under component 1 and (ii) actual
Collection
treatment/destruction/ disposal of 1000 tons of OPs and 3000 tons of PCBs carried out under component 2 of the Project.
Responsibility for Data
Implementing Agency (MoEn) with support from PMU and PIE
Collection
Policies and regulations for the management of PoPs, Hazardous Chemicals and pollution hotspots developed (Number)
This indicator measures the number of policy and regulations supported by the project through sub-components 1.2 and
Description
Component 3(b) for the management of POPs and hazardous chemicals.
Frequency Half-yearly
Data source PMU
Data will be collected and analysed through (i) various assessments, policy, regulations and standards developed by the
Methodology for Data
consultants (ii) review and approval process of MoEn and other GoI institutions under components 1.2, 1.3 and 3 of the
Collection
Project.
Responsibility for Data
Implementing Agency (MoEn) with support from PMU
Collection
Share of POPs monitored through the management information system estagblished through the project (Percentage)
This indicator measures the establishment of management information system through the project and its performance in
Description
monitoring the usage, management and disposal of POPs in Iraq.
Frequency Half-yearly till the system is established and monthly after system is operational
Data source MoEn, MoA and MoElec
Progress of developing the management information system will be monitored based on the progress of work being done
Methodology for Data
by the relevant consultants. Subsequently, establishment of the system and its usage will be monitored based on the
Collection
regular updates shared by the MoEn, MoA and MoElec.
Responsibility for Data
MoEn, MoA and MoElec
Collection
Direct Project Beneficiaries (Number)
This indicator measures the number of people benefitted due to the treatment, disposal and management of OPs and PCBs
Description
through various activities the project.
Frequency After completion of treament and disposal activities at respective locations.
Data source PMU and PIE
Gender disagregated data on the people working and living around the OPs and PCB storage sites that will be treated with
Methodology for Data
Project financing, will be collected from the site owning and managing authorities and local administration. Necessary
Collection
beneficiary surveys will be carried out, if appropriate and adequate information is not available.
Responsibility for Data
Implementing Agency (MoEn) with support from PMU and its consultants
Collection
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Monitoring & Evaluation Plan: Intermediate Results Indicators by Components
Improving the management framework for POPs and hazardous chemicals
Updated National Implementation Plan for POPs prepared (Yes/No)
This indicator measures the completion of inventory and assessment of all POPs and updating the national plan as per the
Description
requirements of Stockholm convention.
Frequency Half Yearly
Data source PMU and PIE
Methodology for Data
Progress reports by the implementing agency and deliverables by the consultants.
Collection
Responsibility for Data
Implementing Agency (MoEn) with support from PMU and its consultants
Collection
Capacity of participating agencies in sampling and laboratory analys of chemicals including OPs, PCBs (Number)
This indictor measures the completion of activities related to procurement of laboratory equipment and capacity
Description
enhancement of the participating agencies to analyze chemical substances including POPs and other hazardous chemicals.
Frequency Half yearly
Data source MoEn, MoA, MoElec
Methodology for Data
Progress reports from MoEn and laboratory analysis reports
Collection
Responsibility for Data
Implementing Agency (MoEn)
Collection
Analytical capacity of Ministry of Environment in sampling and analyis of hazardous chemicals (Number)
Description This indicator measures the capacity of Ministry of Environment in analyzing the number of hazardous chemicals
Frequency Half yearly
Data source MoEn
Methodology for Data
Progress reports from MoEn and laboratory analysis reports
Collection
Responsibility for Data
Implementing Agency (MoEn)
Collection
National Inventory of POPs (OPs and PCBs) completed and system for their tracking and management operational (Yes/No)
This indicator measures the completion of inventory and assessment of POPs (including OPs and PCBs) and establishment
Description
of a tracking system for their monitoring/ management.
Frequency Half Yearly
Data source PIE (on the design) and MoEn, MoA and MoElec on the operation of tracking system
Methodology for Data Outputs and progress reports from the PMU on the tracking systm and monthly reports from MoEn, MoA and MoElec on
Collection the tracking system.
Responsibility for Data
Implementing Agency (MoEn) with support from PMU
Collection
Staff trained in the inventory, assessment and management of pollution hotspots and POPs (Number)
This indicator measures the number of staff trained in the participating ministries in carrying out inventory, testing and
Description
monitoring and management of all POPs and chemical contaminated sites (hotspots).
Frequency Half yearly
Data source Implementing Agency (MoEn)
Methodology for Data
Progress reports from MoEn and PMU
Collection
Responsibility for Data
Implementing Agency (MoEn) with support from PMU
Collection
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Staff trainined in detailed assessment, management and remediatin of hazardous chemical contaminated sites (Number)
This indicator supports training the staff of MoEn in conducting inventories, testing, assessment, management and
Description
monitoring of pollution hoptspots.
Frequency Half yearly
Data source Implementing Agency (MoEn)
Methodology for Data
Progress reports from MoEn and PMU
Collection
Responsibility for Data
Implementing Agency (MoEn) with support from PMU
Collection
Management and disposal of high-risk priority stockpiles of POPs in agriculture and power sectors
OPs contained and/ or dispsosed (Metric ton)
This indicator measures the quantity of OPs disposed through the project as per the requirements of Stockholm
Description
Convention.
Monthly progress review after the commencement of the activity and final estimate after the completion of treatment and
Frequency
disposal activities at respective locations.
Data source PMU and Contractor performing the treatment and disposal operations
Methodology for Data Progress reports from MoEn through PMU and Contractor performing the treatment and disposal operations. Disposal
Collection Certificates and Transboundary Shipment Documents.
Responsibility for Data
Implementing Agency (MoEn) with support from PMU and Contractor performing the treatment and disposal operations.
Collection
PCB contaminated equipment and waste managed and / or destroyed (Metric ton)
This indicator measures the quantity of PCB contaminated substances disposed by the project in compliance to the
Description
requirements of Stockholm Convention.
Monthly progress review after the commencement of the activity and final estimate after the completion of treament and
Frequency
disposal activities at respective locations.
Data source PMU and Contractor performing the packaging and disposal operations
Methodology for Data Progress reports from MoEn through PMU and Contractor performing the packaging and disposal operations. Destruction
Collection Certificates and Transboundary Shipment Documents.
Responsibility for Data
Implementing Agency (MoEn) with support from PMU and Contractor performing the packaging and disposal operations.
Collection
Management of chemical pollution hotspots
Detailed asessments and remeidation plans prepared for high risk priority hotpspots (Number)
This indicator measures the successful completion of detailed assessment and preparation of remediation plans for the
Description
chemical contaminate sites (hotspots) in conflict affected governorates of Iraq.
Frequency Half Yearly
Data source PMU and PIE
Methodology for Data
Outputs and progress reports from Contractors and MoEn
Collection
Responsibility for Data
Implementing Agency (MoEn) with support from PMU and UN Agency
Collection
Project management, Monitoring and Evaluation
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ANNEX 1: Implementation Arrangements and Support Plan & Economic Analysis
COUNTRY: Republic of Iraq
Integrated Persistent Organic Pollutants (POPs) and Chemical Hotspots Management Project
A. Institutional Arrangements
1. The overall responsibility of managing environment policies, programs, and enforcement of legislations in Iraq
rests with the Ministry of Environment (MoEn). The ministry is also the national authority in charge of the global
environmental treaties such as the Stockholm, Rotterdam, Minamata and Basel Conventions and international
programs such as GEF. Among the number of environment legislations in the country, ‘Protection and
Improvement of the Environment Law No. 27 of 2009’ is an umbrella legislation, through which MoEn operates to
perform its regulatory functions.
2. In its earlier form as Ministry of Health and Environment, MoEn has experience in managing World Bank
financed Emergency Environment Management Project (P099809) and COVID 19 Vaccination Project (P177038).
The ministry thus has some, but limited experience and familiarity with Bank fiduciary and ESF requirements.
MoEn also actively works with multilateral agencies such as UNDP, UNEP, etc. on various environment
management projects/ programs and understands the modalities of working with international agencies.
3. Considering its institutional mandate and experience in implementing environmental management activities,
MoEn has been identified as implementing agency for the Project and will be responsible for the, (i) overall
implementation of the project activities; (ii) monitoring the results towards the achievement of agreed outcomes;
(iii) managing the Project according to the agreed procurement and financial management arrangements, (iv)
ensuring the implementation of ESF requirements and agreed ESCP, and (v) complying with all reporting
requirements of the Project as per the GA.
4. MoEn will establish a PMU comprising qualified and experienced technical, financial and procurement
environment, and social specialists compatible to the requirements of the Project activities, to perform the
functions of implementing agency. The PMU will support MoEn in the overall planning, implementation and
management of Project activities and will supervise the implementation of activities by the consultants,
contractors, and other agencies.
5. To further support the Project implementation, MoEn will engage UNDP or other UN Agency for management
and implementation of Components 1, 2 and 3. For this purpose, MoEn will sign an output agreement with the
selected UN Agency to execute the activities as designed by the Project. MoEn has initiated discussions with UNDP
for this purpose, however a flexible approach is being adopted, so that the government can sign the agreement
with any other UN Agency subjected to prior approval of the Bank. The PMU at MoEn will oversee the activities
of the selected UN Agency in close coordination with the GoI, particularly with the relevant ministries and all
stakeholders, with an objective to build their capacity.
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6. MoEn will establish a Project Steering Committee (PSC), to facilitate coordination and active participation of
various agencies, ministries, and other stakeholders and monitor the overall implementation of the Project. The
PSC will be established in consultation with GoI ministries, departments, agencies, and other stakeholders relevant
to the Project and will include MoEn, MoA, MoElec, Ministry of Oil, Ministry of Industry and Minerals, Ministry of
Planning, Ministry of Science and Technology, Ministry of Finance, and other stakeholders as needed.
7. A POM has been prepared to guide the implementation of the Project. The POM describes in detail, the
implementation arrangements; roles and responsibilities of the MoEn, PMU and other participating agencies;
agreed Fiduciary and ESF procedures; overall implementation plan; progress reporting requirements and
arrangements for the monitoring and measurement of results.
8. MoEn will be responsible for results monitoring and will ensure continuous monitoring of Project
implementation with support from PMU and in close collaboration with local partners and assess progress
towards the achievement of the end targets agreed in the results framework. As per the M&E Plan of the Project,
an expert will be recruited under Component 4 of the Project and will be responsible for performing the M&E
functions. MoEn will report on implementation progress and achievement towards the targets stipulated in the
Results Framework on a half-yearly basis to the WB. The POM developed for the Project includes the approach
and methodology proposed to be followed for monitoring the results.
9. The Bank will undertake Implementation Support missions twice a year to monitor implementation, compliance
with environmental and social provisions, and will evaluate Project performance according to established
performance monitoring indicators. Considering security situation in the Iraq, physical or virtual or reverse
missions will be organized, as appropriate. The implementation support missions will include field visits and
discussion with relevant stakeholders, government agencies and implementing agencies. All Project monitoring
reports would be made public in accessible forms.
10. In addition, a Third-Party Monitoring Agency (TPMA) will be engaged by the Bank to monitor Project activities.
The TPMA will report on the progress of all activities, outputs, status of achieving the results and the fiduciary and
ESF implementation. The TPMA will share its monitoring report with the World Bank and the findings of the report
will be discussed with MoEn and corrective actions with timelines will be agreed. MoEn accordingly will submit a
report on the corrective actions taken to address issues identified by the TPMA to the World Bank.
11. A Mid Term Review of the Project will be conducted three years after Project effectiveness and an Implementation
Completion and Results Report will be prepared within six months of the Project closing. Prior to these, MoEn will
conduct its own review of the Project progress and implementation performance.
B. Procurement
12. Applicable Procurement Regulation. Procurement activities will be conducted in accordance with the: “The World
Bank Procurement Regulations for IPF Borrowers. Procurement in Investment Project Financing, Goods, Works,
Non-Consulting and Consulting Services” 5th edition, dated September 2023. The Borrower will also ensure that
the Project is conducted in accordance with the provisions of the “Guidelines on Preventing and Combating Fraud
and Corruption in Projects Financed by IBRD Loans and IDA Credits and Grants,” dated October 15, 2006, and
revised in January 2011 and as of July 1, 2016 (“Anti‐Corruption Guidelines”).
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13. Key procurements under the Project. The Project activities under components 1,2 and 3 will be providing
technical assistance, knowledge management, institutional strengthening and capacity building, and advisory
services, as well as procuring essential facilities, equipment to support the technical assistance. The Project will
also finance works to manage and dispose of hazardous waste. The MoEn will engage UNDP or other UN Agency
to support the management and implementation of part of the Project activities, and will sign an output
agreement with the UN Agency, using standard agreement. Component 4 will finance a few simple and small-
value procurement of goods and consultants’ services for Project management, M&E.
14. Procurement implementation arrangements. The MoEn will be responsible for overall Project procurement
activities through the PMU that will be established to include, among others, a Project coordinator (technical),
procurement, and financial officer. The MoEn has limited experience in Bank financed projects and procurement
regulations, with little experience in procurement planning, monitoring, and contract management; therefore,
the PMU will need to be supported by an experienced procurement specialist, to provide support during the whole
procurement cycle including hiring UNDP or other UN Agency and supervision of its contract. The POM includes
the detailed project procurement arrangements and applicable thresholds.
15. Project Procurement Strategy for Development (PPSD). In line with the requirement of the Procurement
Regulations, a PPSD including a comprehensive, fit-for-purpose Procurement Plan for the first 18 months of the
Project has been prepared by MoEn with WB support. The provisions of the Recipient’s procurement plan for the
Project (“Procurement Plan”), as elaborated under Section IV of the Procurement Regulations, will apply, and the
same may be updated from time to time in agreement with the World Bank.
16. Systematic Tracking of Exchanges in Procurement (STEP). The PMU at MoEn shall use the World Bank online
procurement planning and tracking tool (STEP), to prepare, clear and update its procurement plans and conduct
procurement transactions as referred to in the Procurement Regulations Section V, article 5.9. The details for the
first 18-month procurement plan had been finalized with the Recipient and will be published on the World Bank
website through STEP. The Bank’s procurement team will provide training and close support.
17. Advance procurement. To speed up Project implementation, advance procurement is key and may apply to: (1)
prepare ToRs; (2) advertise expressions of interest; (3) identify qualified consultants; (4) launching procurement
process to engage UNDP or other UN Agency up to award of contract.
18. Procurement Risks and mitigation measures: Procurement risk is considered as “High”, and main risks are
identified as : (i) lack of experience of MoEn in working with WB-financed projects; (ii) limited capacity of the
implementing agency (MoEn) in World Bank procurement policy and procedures, procurement planning and
management contracts, (iii) the socio-economic and political situation of the country; (v) high perception of fraud
and corruption in a high risk and weak control environment, (iv) complexity of coordination with other concerned
stakeholders such as ministries and other public institutions; and (v) possible delays in implementation due to the
security conditions in Iraq, long decision-making process, and delay in registration of contracts in MOP national
investment budget, and (vi) restricted travel/mobility of WB staff and difficult to supervise project sites; with weak
internet connectivity to use WB’s mandatory systems, such as Client Connections, STEP, etc.
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19. The following measures are proposed to mitigate these risks: (i) hiring a qualified procurement consultant to
support the PMU in conducting procurement activities and contract management; (ii) hiring UNDP or other UN
Agency to support MoEn in delivering the services required under components 1,2 and 3 and the contract with
UN agency, regardless of the value, will be subject to Bank’s prior review; (iii) introduce flexibility in the
qualification criteria, and appropriate packaging to be set based on market analysis; (iv) describe in detail and
follow the procurement processes and procedures in the POM; (v) MoEn should commit to ensure the contracts
are included in the national investment budget plan as needed and (vi) use of technology to conduct virtual online
missions and MoEn shall ensure access to high speed internet to utilize systems. Another foreseen risk is potential
delays due to GoI’s internal processes and approvals. This risk would be mitigated by advance planning and
delegation of authority at appropriate levels as well as a commitment by GoI to comply with agreed procurement
and implementation plans.
20. Procurement method and Prior Review threshold. Based on the assessment, the procurement plan shall set forth
those contracts subject to the Bank’s prior review for High-risk risk environment. All other contracts shall be
subject to post-procurement review by the Bank. The Table below provides the thresholds for each type of
procurement.
Prior Review Thresholds
Type of Procurement Prior Review High-Risk Thresholds (US$ million)
Civil Works 5.00
Goods, information technology & non-consulting services 1.50
Consultants—firms 0.50
Consultants—individuals 0.20
Contract with UNDP or other UN Agency Regardless of the Value
C. Financial Management
Financial Management Assessment
21. The financial management arrangements at the MoEn were reviewed by the Bank team. Based on the result of
the assessment, the FM risk, as a component of the fiduciary risk, is rated as ‘High’. With the proposed mitigation
measures, MoEn will have the FM requirements and will have an acceptable FM system, and the residual FM risk
rating would be ‘Moderate’. The following are the risks identified.
▪ Difficulties in opening a project designated account.
▪ Overall weakness and shortcomings in the control environment including banking system.
▪ MoEn has internal bylaws and procedures, however they do not meet Bank requirements.
▪ MoEn does not have accounting software to record transactions and produce financial reports.
22. To mitigate these FM risks, the following mitigation measures are proposed:
▪ MoEn shall request the funds to be channeled from the Bank to the third-party using direct payments and UN
advance through withdrawal applications accompanied by proper supporting documentation.
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▪ The Bank will engage a TPMA to validate that the services and activities have been conducted as per the
provisions of the Grant Agreement, Project Appraisal Document, and the POM.
▪ MoEn will utilize a ring-fenced system to implement the Project and will utilize excel spreadsheets to record
daily transactions and produce the quarterly financial reports.
▪ MoEn prepared a POM which includes a FM chapter.
▪ Quarterly IFRs will be submitted within 45 days after the end of each quarter to the Bank.
▪ MoEn will get into a contract with an independent external financial auditor with terms of reference
acceptable to the Bank to audit the Project Financial Statements (PFS). The financial auditor will prepare an
audit report and management letter that will cover the financial operations, internal control and financial
management systems and a comprehensive review Statements of Expenditures (SOEs) and will be due no later
than six months after the end of each fiscal year.
23. The MoEn will assign/recruit a Financial Officer who will be responsible for handling the FM aspects of the
Project under the supervision of the MoEn Project Manager. The project funds will be disbursed in USD and local
currency and will be channeled from the World Bank to the third-party upon PMU’s request. Funds will be
channeled from the World Bank using direct payments and UN advance disbursement methods through
withdrawal applications accompanied by proper supporting documentation. Disbursement will be following the
applicable procedures and the World Bank's Disbursement Handbook. IFRs and annual PFS will be used as a
financial reporting mechanism, whereas Statement of Expenditures will be used for disbursement purposes. The
Bank will provide the PMU with training and hands-on support to implement the FM activities.
Summary of FM actions to be implemented
Actions Deadline
Finalize FM chapter of the POM 3 months after effectiveness
Assign team for the Project including a financial officer 1 month after effectiveness
Hire an independent external financial auditor 6 months from effectiveness
D. Economic Analysis
24. Background. The Project is expected to produce tangible and intangible benefits although only the former is
quantified and valued. The intangible investments strengthen the enabling environment (planning and
management process, capacity building, etc.) which are essential for safely discarding to generate economic
benefits in terms of prevented mortality and morbidity by reducing the health risks associated with keep these
materials in unsafe storage. The benefits will accrue on: (i) workers handling those substances; (ii) local
communities including women who may be exposed through contact or from contaminated water or food or
inhalation in case these harmful substances are accidentally burnt; and (iii) the global environment from reduced
accidental exposure from the release of dioxins and furans into the atmosphere. The development of an enabling
environment yields intangible assets, with benefits that are difficult to quantify. For that reason, the ex-ante
economic Benefit-Cost Analysis (BCA) considers only the more quantifiable health benefits associated with the
safe discarding of the POPs and PCBs. Moreover, other World Bank POPs and PCBs projects are reported below to
compare costs of safely handling POPs and PCBs. These would not only serve to benchmark interventions and
guide the implementation of the Project, but also be used for the ex-post cost-effectiveness analysis.
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25. Cost Effectiveness Analysis to Benchmark Project Interventions and Guide Project Implementation. A Cost
Effectiveness Analysis for handling, treating, and disposing of all POPs and PCBs was not carried out as cost
alternatives still need to be calculated. Yet, other POPs and PCB cleanup projects are mentioned for ex-post
benchmarking. The following projects focused on the repackaging, transport and disposal of POPs and treatment
of PCBs: (i) Moldova POPs Stockpiles Management and Destruction Project (P090037) where the cost per ton of
PCBs eliminated was US$4,200; (ii) China PCB Management and Disposal Demonstration Project (P082993) where
each ton of eliminated PCB costed US$4,100; (iii) Lebanon PCB Management in the Power Sector Project
(P122540) where the average cleanup cost was US$2,125 per ton; and (iv) Egypt’s Sustainable Persistent Organic
Pollutants Management Project (P116230) where the cost of OPs exported was US$1,577 per ton on average, the
average cost of OPs incinerated locally was US$311 per ton and the cost of PCBs exported was US$5,935 per ton
including decontamination units, customs, PCB analysis and training.
26. Rapid Literature Risk Factors’ Review. International studies have shown increased risks of cancer, with malignant
melanoma and other specific forms of cancer being of particular concern in the energy industry.13,14,15 For all-cause
mortality, the evidence is more mixed prevalence rates cannot always be shown to be higher than national
averages, which leads us to believe that occupational long-term high-level airborne and dermal exposure to
commercial PCB mixtures is probably not associated with increased overall risk for cancer, but an elevated risk of
rare cancers.16 For the purposes of the BCA, this uncertainty leads us to assume that the occupational exposure
risk is no larger than the environmental risk posed to the local community.
27. A study in Sweden found that POPs were associated with an increased mortality risk,17 where individuals with the
highest PCB levels had 50 percent excess mortality, especially from cardiovascular disease, compared with the
other groups. Overall, elevated PCB levels in the blood corresponded to 0.7 excess deaths per year of the exposed
population after 10 years.
28. Scope of benefit cost analysis and Assumptions. The primary quantifiable benefits of the Project are assumed to
be the prevention of lost productivity due to excess mortality by the workforce in the electricity sector and the
population surrounding contaminated sites. Other lost productivity costs related to occupational exposure, cost
of illness, as well as accidental exposure during clean-up, are not included in the analysis.
29. The target beneficiaries amount to 7.05 million and are illustrated in Table below by site.
13 Loomis et al. (1997)
14 Prince et al. (2006)
15 Rudera et al. (2014)
16 Bøtker Pedersen et al. (2013)
17 Lind et al. (2019)
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Project beneficiaries by type of substance and location
Target Area Population Beneficiaries
OP sites 466,000 80,500
Suwaira warehouse 161,000
Khan Dhari site 305,000
PCB sites 18,271,269 6,973,057
Ninewa Production and Transmission Station sites 3,700,000
Kirkuk Production and Transmission Station sites 1,031,000
Qadisiyah Production and Transmission Station sites 348,700
Diwaniyah Transmission Station sites 650,927
Hilla Production Station site 364,700
Najaf Production and Transmission Station sites 1,000,000
Al Musieb Production Station site 89,000
Baghdad Production and Transmission Station sites 7,665,000
Hamren Production Station site 25,000
Sad Hadeitha Production Station site 46,500
Basra Production Station sites 1,400,000
Al Nasseriya Production Station site 560,000
Babylon Production Station site 2,065,042
Karbala Transmission Station sites 690,100
Total 18,737,269 7,053,557
30. Key assumptions considered for the analysis included the following.
▪ Although the economic analysis assesses the Project on its own merits, Project costs are not adjusted for price
distortions and include taxes.
▪ An actual discount rate of 6 percent per annum for economic analysis over 25 years.
▪ All benefits are calculated in 2023 constant prices.
▪ The beneficiaries are the cohort that is considered at the end of the Project.
▪ Mortality rate of averted 0.07 percent is considered for all Project beneficiaries.
▪ Benefits accruing from reductions in excess mortality begin 10 years after Project closure for the next 10 years.
▪ Value of statistical life for the reduction of risk of premature deaths in Iraq as US$386,782 in 2022 for each
premature death and GDP per capita at US$4,891.
31. The economic analysis is performed by using a 6 percent social discount rate over 25 years based on the
opportunity cost of capital and country risk over the Project period. A sensitivity analysis is performed under a
pessimistic scenario (a 10 percent increase in economic costs and a 10 percent decrease in benefits over the base
case and an 8 percent discount rate) and an optimistic scenario (a 10 increase in benefits and a 10 percent
decrease over the base case and a 4 percent discount rate). In addition, Project viability switch-off points for equal
cost increment and benefit decrement, cost increment, and benefit decrement are computed.
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32. Benefit Cost Analysis Results. The Table below summarizes the results of the economic analysis. The Project is
viable under all three scenarios with a net present value far exceeding the investment costs. The base case
scenario has a positive Net Present Value of US$386.7 million as well as a robust Internal rate of return of 23
percent and positive Present Value benefit-cost ratio of 28.1. The Project, which remains viable under the
optimistic and pessimistic scenarios, is more sensitive to a decrease in benefits than to an increase in costs under
the viable scenarios that are reflected by the switch-off points.
Cost/Benefit, Sensitivity, and Scenario Analysis Summary
Key Economic Indicators Project
25 Years Discounted At
Scenario Optimistic @4% Base Case @6% Pessimistic @8%
Cost/Benefit Analysis
NPV (US$, millions) 655.20 386.70 203.40
IRR (%) 23% 23% 22%
PV benefit/cost ratio 43.20 28.10 15.00
Viability Yes Yes Yes
Sensitivity Analysis Benefit + 10%, Cost -10% Cost + 10%, Benefit -10%
NPV (US$, millions) 723.80 386.70 239.10
ERR (%) 24% 23% 23%
PV benefit/cost ratio 52.80 28.10 16.90
Switch-off point
>cost = <benefit (±%) ±96 ±93 ±88
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