INTEGRATED SAFEGUARDS DATASHEET APPRAISAL STAGE

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1 Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized I. Basic Information Date prepared/updated: 05/21/2009 INTEGRATED SAFEGUARDS DATASHEET APPRAISAL STAGE Report No.: AC Basic Project Data Country: Bulgaria Project ID: P Project Name: Municipal Infrastructure Development Task Team Leader: Gabriel Ionita Estimated Appraisal Date: May 18, 2009 Estimated Board Date: July 21, 2009 Managing Unit: ECSSD Lending Instrument: Specific Investment Loan Sector: General water, sanitation and flood protection sector (100%) Theme: Other urban development (100%) IBRD Amount (US$m.): IDA Amount (US$m.): 0.00 GEF Amount (US$m.): 0.00 PCF Amount (US$m.): 0.00 Other financing amounts by source: Borrower Environmental Category: A - Full Assessment Simplified Processing Simple [] Repeater [] Is this project processed under OP 8.50 (Emergency Recovery) or OP 8.00 (Rapid Response to Crises and Emergencies) [ ] No [] 2. Project Objectives The project objectives are to: (a) Improve the reliability and quality of water provision to the communities in selected settlements in the project area, and (b) Assist municipalities to improve investment-planning capacity. These objectives are in line with Bulgaria s National Strategy on Environment ( ) which has a goal to "provide good quality and sufficient quantity of water for various purposes". 3. Project Description The project will have three components: Component 1 (Total Cost Euro 5.12 million): Project Implementation Support to carry out activities under Component 3 of the project and completion of project audits. These would include preparation of feasibility studies, updates of design and Environmental Management Plans, preparation of bidding documents, construction supervision and other consulting assignments needed for project support, including a communication plan to help ensure people are aware of the status of land issues. Component 2 (Total Cost Euro million): Preparation of Master Plans in 48 water and wastewater regional utilities. The Master Plans will help identify investment needs for rehabilitation of water supply network and construction of sewerage network and

2 wastewater treatment plants in each ViK. The information from the Master Plans would be used to prepare investments that would help Bulgaria meet the relevant EU water and wastewater directives. The Master Plans will also comprise corporate development plans and any other related documents and activities promoting improved service delivery and greater efficiency. Component 3 (Total Cost Euro million): Completion of three water supply dams and rehabilitation of a fourth dam that is currently operational. This component will also support the completion of water treatment plants preparation work included in the dam investments and construction supervision. The feasibility studies for the dams will be completed during project implementation so cost estimates are based on an earlier assessment and physical contingencies. 4. Project Location and salient physical characteristics relevant to the safeguard analysis Eligible activities under Component 3 include the rehabilitation of the Studena dam and the rehabilitation and completion of three water supply dams Luda Yana, Neikovtsi, and Plovdivtsi where construction had ceased in The dams are located in mountainous areas and built on streams which collect several small tributaries before finally reaching Maritza or Danube rivers. These tributaries are characterized by uneven seasonal flow reaching high waters in spring during snow melting season and almost no water during summer. Villages including an average of 15,000 people are located within less than one km (Neikovtsi); two km (Luda Yana) and 400m (Neikovtsi) in distance from the respective dam sites. Some of these settlements have constant tourist attractions including historical buildings (e.g., Panaguriste). The current environmental physical characteristics at the 3 dam sites are impacted by the constructions works performed earlier, which stopped when about 60-70% of the facilities were raised. The areas underwent partial deforestation and topsoil removal and currently show signs of erosion, scarce vegetation, soil excavations and other impacts from uncovered quarries. There are no critical natural habitats or endangered/threatened species at the dam sites, within the inundation areas or in the impact zone of the dam downstream. Based on existing information it is expected that only the protective sanitary zones of the dams reservoirs will overlap with PAs (to be confirmed during detailed design), and the management regime for such protection zones are compatible with PA management. 5. Environmental and Social Safeguards Specialists Ms Radhika Srinivasan (OPCFC) Ms Ruxandra Maria Floroiu (ECSSD)

3 6. Safeguard Policies Triggered No Environmental Assessment (OP/BP 4.01) Natural Habitats (OP/BP 4.04) Forests (OP/BP 4.36) Pest Management (OP 4.09) Physical Cultural Resources (OP/BP 4.11) Indigenous Peoples (OP/BP 4.10) Involuntary Resettlement (OP/BP 4.12) Safety of Dams (OP/BP 4.37) Projects on International Waterways (OP/BP 7.50) Projects in Disputed Areas (OP/BP 7.60) II. Key Safeguard Policy Issues and Their Management A. Summary of Key Safeguard Issues 1. Describe any safeguard issues and impacts associated with the proposed project. Identify and describe any potential large scale, significant and/or irreversible impacts: OP/BP 4.01 Environmental Assessment: the project is rated as environmental assessment category A because the completion of the three dams could potentially have adverse impacts on the upstream or downstream environment. Possible environmental impacts are divided into those related to temporary aspects during construction works and possible long-term impacts due to the existence of the reservoir and dam and its operation overall. The previous construction has significantly affected the three dam sites. The additional construction related impacts during completion of the dams are likely to be localized and can be prevented or reduced to acceptable levels by applying international construction practice and planning. Such potential impacts may be related to: (i) air pollution/dust, noise, vibration, and access restriction, (ii) improper disposal of construction related waste; (iii) temporary pollution of soil and surface waters due to accidental spillage of fuel and oil from construction activities; (v) safety hazards including worker safety; (vi) damage to trees and existing vegetation, and (vii) chance finds of physical cultural resources. However, these impacts will be properly managed during the construction phase by the contractor and closely supervised by PIU and designated supervisor engineer. Potential environmental effects due to the existence and operation of the future dams and reservoirs may be related to: (i) changes in downstream morphology of riverbeds and banks due to altered sediment loads of the rivers that would result in increased local erosion; (ii) changes in downstream hydrology (total flows, seasonal flows, short-term fluctuations); (iii) changes in downstream water quality (e.g., nutrient load, concentration of heavy metals, temperature); (iv) reduction of biodiversity and river ecosystems due to blockage of movement of local species (e.g. fish) and because of elimination of floods; and (v) impacts on existing infrastructure such as roads and bridges. These impacts are expected to be moderate and manageable as indicated in the EIAs/EMPs for each site. In order to study the potential impacts of the project and to propose related mitigation measures to address such impacts during construction and operation of the proposed

4 dams, the Borrower prepared the following environmental safeguard documents to meet the OP/BP 4.01 requirements: a) An Environmental Management Framework (EMF) that describes the project environmental assessment process to be followed by Government during implementation (this EMF was prepared in anticipation of the possible revisions that the EIAs prepared for project appraisal - and specially EMPs - for the 3 dams could undergo once feasibility studies and detailed designed are updated during project implementation); b) Three Environmental Due Diligence (EDD) Reports reflecting briefly the environmental situation in October 2007 at the three incomplete dam sites where works stopped some years ago due to lack of finances; c) Environmental Impact Assessments (EIAs) for Luda Yana and Neikovtsi dams, including Environmental Management Plans (EMP) were developed based on the EDD Reports and new site investigations in September For the Plovdivtsi Dam, an EIA was approved by Ministry of Environment in accordance with the Bulgarian legislation, in 2000, based on which construction permit was issued. However, a Supplemental Update EIA acceptable to the Bank was prepared by the Borrower to meet OP/BP 4.01 requirements. All these 3 EIA documents were subject to review by the Bank and finalized accordingly by the Client prior to project appraisal. These final documents were also disclosed in country and at the Infoshop and will be updated based on the revised feasibility studies to be completed at the beginning of project implementation; and d) A stand-alone EMP for the rehabilitation works proposed at Studena dam. These reports were developed based on information provided by the existing, old feasibility studies and detail designs as well as visual assessments of the existing sites. The documents summarize each dam history, include option analysis, identify the legislative and organizational structures for environmental management; describe the existing environmental and social conditions and the anticipated environmental impacts during dam construction and operations. They also outline the environmental impact mitigation and monitoring plan; and describe the public consultation process. One of the important mitigation measures for the operational period will be the maintenance of an environmental flow adequate to maintain downstream environmental conditions. The basis for calculating the required flow is a model that is detailed in the EIAs and was found to be acceptable by the Bank. Once the feasibility studies and detail designs are updated during project implementation, the EMPs and EIAs if necessary will be revised to reflect any new engineering documentation and information collected during the process. In the case of Luda Yana dam site, the EIA does not currently cover potential impacts of the construction of the water treatment plant. The precise location and design for this plant will be determined during project implementation and a separate EMP will be prepared for it. During the preparation of the above noted environmental safeguard documents two rounds of public meetings were held at the national and local level, in October-December 2007 and February OP/BP 4.12 Involuntary Resettlement: The bulk of the land required for the main dam wall, dam lakes and corresponding submerged area, ancillary structures and adjacent

5 infrastructure has previously been acquired by the Government of Bulgaria in the years between 1982 and 2000, before initial discussions between Government and the Bank about financing completion of the dams. Therefore, while the previous land acquisition is linked to construction of the dam, it is not linked to the project. A deadline of May 14, 2007 for land restitution claims was set by and in accordance with the Agricultural Land Ownership and Use Act 1991 and the Act Restoring Ownership on Forests and Forest Stock Land Tracts from the Forestry Fund, On this basis, OPCQC, LEGEN and the Region concluded that the past land acquisition is a legacy issue and not a current issue, and OP 4.12 does not apply to it. As good practice, during preparation the Bank sought information on the past land acquisition and resettlement activities and this is available in the Social Due Diligence (SDD) reports for the three dams. Land that has been or may in future need to be expropriated includes the site of the dams, their respective reservoir areas, and the area of the Sanitary and Security Area Belt I (SSA-Belt 1) sanitary zones. A Land Acquisition Policy Framework (LAPF) has been prepared to address the requirements of future land acquisition. The LAPF was disclosed in country and in Infoshop in December 2007 (as indicated in Section II B). It was updated and finalized and the final version disclosed in country and in Infoshop in March For civil works associated with MIDP, it is likely that limited acquisition may result in the loss of land or the loss of sources of income and cash compensation will be provided. People are not expected to lose their residences or other structures. In all three dam areas, there is informal use of the land, primarily for grazing animals, and the local authorities have agreed that alternative land for grazing purposes would be provided to the affected people. The government has indicated October 26, 2007 (the last date of the survey) as a cut-off date after which any person carrying out illegal informal activities in the area is not eligible to receive any assistance. The SDD and the LAPF were publicly discussed at the national and local levels in October-December 2007 and February 2009 and have been publicly disclosed on March 24, Although no such cases have been identified to date, the LAPF covers cases in which an initial restitution claim was made prior to the deadline of May 14, 2007, but which have not yet been resolved. The LAPF applies to Component 2. The outputs of TA under Component 2 are expected to be only at a pre-feasibility level of detail, with feasibility studies, detailed designs and investment to follow later and be financed separately, possibly with assistance from EU. However, the TA provided under Component 2 involves preparation of site assessments including specific recommendations for sitting of facilities that, if followed, could involve expropriation of land. The TA will therefore provide all information needed to apply the processes outlined in this Policy Framework to the acquisition of any such land. Based on the information available it is not expected that people might (in the context of this project) seek to revive previously rejected restitution claims or seek additional compensation for past expropriation. A communication plan will be put in place under Component 1 to clarify that the LAPF is applicable to future land acquisition, not to past actions, and thereby to reduce the risk of perception of linkage between past expropriations and the project. The Government and Bank agreed to inform each other

6 on any claim or complaint regarding past land expropriation and/or restitution that may arise in relation to the Project sites. While such claims will not be subject to the provisions of LAPF, the Government will inform and discuss with the Bank the measures to be taken to find an equitable resolution to such potential claims or complaints in accordance with the Bulgarian laws and regulations. OP/BP 4.37 Safety of Dams: due to the completion of the Luda Yana, Neikovtsi, and Plovdivtsi dams and the rehabilitation of the Studena dam, the policy will be triggered. Bulgarian dam safety requirements are in line with those of the Bank and for the project design, construction, and operation the Bulgarian legislation and Bank policies will be followed. Prior to appraisal, the Government appointed a panel of three national experts on dam safety that provided comments on the Terms of Reference for the feasibility studies related to the dams and will further review the feasibility studies and engineering designs and provide guidance during implementation of works, whenever necessary. In order to address the safety of constructed dams, the Borrower will prepare Emergency Preparedness Plans for each dam site during project implementation (as part of the updated feasibility studies), including action plans in case of seismic or hydrological risks. In addition, during preparation of designs for the new dams, the Borrower will prepare a Plan for Construction Supervision and Quality Assurance, and an Instrumentation Plan, which will be reviewed and endorsed by the Panel of Experts on Dam Safety before tendering for construction. Once the designs are ready, the Borrower will draft an Operation and Maintenance Plan, which will be refined during implementation and finalized at least six months before first filling of the reservoirs. OP/BP 7.50 Projects on International Waterways: The policy is applicable due to the completion of the following dams as they are located on streams that eventually discharge to riparian countries or international waterways as follows: (i) the Luda Yana dam is constructed on the Luda Yana stream which is a tributary of the Maritsa River that forms a border between Turkey and Greece and finally discharges into the Aegean Sea; (ii) the Neikovtsi dam is constructed on the Neykovska and Sarbogaska streams, which are tributaries of the Trevnenska River, which discharges in the Yantra River, that flows eventually into the Danube, and (iii) the Plovdivtsi dam is constructed on the Iskretska stream, which is a tributary of the Arda River that flows into the Maritsa River. However, given the relatively small volume of the water retained in the dams compared to the flow of the rivers that exit Bulgaria, there would be no adverse effect on water quantity and quality for other riparian countries. Although the works financed under the Project will not cause any adverse downstream effects to any international waterways, as per the Bank s OP 7.50, through a letter dated March 19, 2008, the Bulgarian Government has authorized the Bank to notify the riparian states about the project. Through letters dated March 21, 2008, the Bank, on behalf of the Government, has informed Turkey, Greece, and the International Commission for the Protection of the Danube River about the earlier version of the project. (The current project design differs from the one finalized in February The earlier design included a component to rehabilitate water supply networks in six regional water utilities and technical assistance to utilities to implement the project and increase operational efficiency. The Government of Bulgaria subsequently requested changes to the project design that are reflected in the current project.)

7 Furthermore, there has been an exchange of letters between the Bank and Government of Turkey (GoT) regarding the construction of dams and the summary follows: - Through a letter dated May 30, 2008, the GoT sought additional information on the project; - Through a letter dated June 19, 2008 the Bank provided references to the publicly available documents on Environmental Due Diligence and Social Due Diligence documents and hard copies of these documents were also provided. The Bank requested that GoT provide any comments by July 21, 2008; - Through a letter dated July 8, 2008, the GoT requested that additional time be provided to review the documents; - Through a letter dated July 15, 2008, the Bank requested that any comments should be provided by September 5, 2008; - Through a letter dated September 2, 2008, the GoT noted their general concern regarding potential adverse impact of the project concerning water quality and quantity, bio-capacity for cropland, grazing land and forest related to the proposed dams. Other comments were raised regarding the need for the dam designs to consider adequate capacity to "absorb flooding"; the dam management should take into account the river basin capacity as well as downstream water demand in various months; and the hydraulic and meteorological data should be provided by Bulgarian authorities to Turkey on a regular basis. Further, any irregularities in flow should be reported through the Center of Early Warning Mechanism formed between the two countries. The GoB already maintains a designated minimum flow, provides reports on water releases to the GoT in keeping with existing agreements and will continue to do so with regard to the three dams after their construction is completed. The Borrower and World Bank agreed that the World Bank will maintain communication with the riparian countries related to final EIA findings. The final EIAs for the three dams were publicly disclosed on the website of MRDPW and in Washington at the Infoshop on May 12, The World Bank sent the updated information on the project, including the final EIAs, to riparian countries and the International Commission on Danube River Protection on May 13, The riparian countries have been requested to reply to the information provided in the letter by June 15, OP/BP 4.04 Natural Habitats Natural Habitats will apply since small areas of one or more of the dam sites may fall within Protected Areas (also Natura 2000 sites). Based on existing information it is expected that only the protective sanitary zones of the dams will overlap with PAs, and the management regime for such protection zones are compatible with PA management. This will be confirmed during preparation of the feasibility studies and detailed designs, and the updated EMPs will include any required mitigation measures to ensure that local biodiversity is not adversely affected. The OP/BP 4.36 Forestry is not triggered, although a few trees must be removed from the future reservoir basins once civil works begin, these trees are sparse and scattered, left over from vegetation clearing years ago during the initial dam construction, and do not

8 constitute a forest. Near the crest of Luda Yana dam, about 0.6 ha of trees will be removed when dam construction resumes. OP 4.11 Physical Cultural Resources policy is not triggered because the investigations conducted during EDD and EIA preparation process raised no concerns regarding potential chance finds of cultural properties at the proposed dam sites. However, the EMPs include provisions for cultural heritage and archeology if chance finds occur during construction works. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area: Completion of the dams with associated site restoration and water regulation will result in a significant improvement over existing environmental conditions, which continue to reflect impacts of previous construction. Potential long-term environmental changes could appear in relation with the creation of lakes upstream of the dams where the water would be stored and with the release patterns from these reservoirs. Associated impacts might affect local resources such as fish, recreation and hydropower activities. However, the anticipated reservoir areas do not include critical habitats and the retention volumes and reservoir areas are not expected to be significant enough to create significant environmental damage (Plovdivtsi dam mln. m3; Neikovtsi dam mln. m3; and Luda Yana dam mln. m3). The possibility of developing hydropower plants around these dams is not excluded and this could trigger further indirect impacts. Also, once the dams are built, its modern automatic technology and operation demands a relatively small number of employers, which must have special training and technical expertise. 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. Because a significant amount of construction has already taken place at each of the three dam sites (up to 70% completed) it is not practical to consider alternative sites. The EIAs summarize options that were considered in the original feasibility studies and designs, such as rehabilitation of existing water supply sources, alternative sites for the dams, types of dam walls and related facilities, etc. and the reasons for the choices which were made. The EIA noted that the "no-project" alternative (leaving the partially completed dams in place with no further investment) is undesirable for two reasons. On the one hand, because of the urgency of addressing the acute shortage of drinking water for affected populations (some 80,000 people) and, on the other hand, because in the absence of further investment the construction and reservoir sites would be left in their present damaged condition and would not be remediated. However, the updated feasibility studies will confirm whether the completion of these dams remains the most economical way to meet the areas water supply needs. 4. Describe measures taken by the borrower to address safeguard policy issues. Provide an assessment of borrower capacity to plan and implement the measures described. Current Bulgarian legislation requires preparation and approval of EIAs for new dam construction. Since constructions at 2 dam sites (Luda Yana and Neikovtsi) started more

9 than 10 years ago and under a different Water Law, no EIAs for these works were required and there was no requirement under current Bulgarian EIA legislation to prepare them at this time. However, in order to meet the OP/BP 4.01 requirements, these EIAs have been prepared (October 2008). For the Plovdivtsi Dam, an EIA was approved by Ministry of Environment in 2000, based on which construction permit was issued, however there were some gaps with respect to requirements for a Category A EIA under OP 4.01 and a Supplemental EIA document has been prepared to fill these gaps. The environmental and social safeguards disclosed during project preparation are: Environmental Due Diligence Reports (2007); Social Due Diligence Reports (2007); updated Land Acquisition Policy Framework (2009); draft Luda Yana and Neikovtsi EIAs and the Plovdivtsi Supplemental EIA have been disclosed in local language and discussed in public meetings ( February 2009). The final EIA documents were disclosed in country and Infoshop (replacing the existing draft versions), and the Executive Summaries were submitted to Board on May 12, 2009 (before project appraial). The implementing agency will be the Ministry of Regional Development and Public Works (MRDPW). The ministry has the institutional capacity in Sofia and in the regions to implement the project satisfactorily, including addressing safeguard issues. Within the MRDPW, the PIU newly established within the Water and Sewerage Department will be responsible for day to day implementation of the project and will include a technical expert responsible for safeguards due diligence; overall, the PIU will ensure that the institutional and financial capacities of the ministry are used to address and manage environmental issues of the project. 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. The key stakeholders include the project-affected population, relevant NGOs, dam safety and ecology protection experts, municipalities of the 3 project dam sites, representatives of GoB including MRDPW and MoF. In October 2007, public consultations were held on EDD and SDD reports at the project sites where the dams would be finalized. The local population is supporting the completion of the dams as the project activities had ceased since 2001 without yielding the benefit of provision of uninterrupted supply of quality drinking water. Local residents mentioned that they face water rationing and look forward to the completion of the dams. A national level consultation, including non-government groups and various stakeholders, was also carried out on December 12, 2007 where the participants expressed interest in the project and to date there has been no opposition to the proposed dam investments. Furthermore, the results of the EIAs for Luda Yana, Neikovtsi and Plovdivtsi were presented to the affected population at national and local level during February 2-13, Public views were solicited regarding employment opportunities during construction and operation of the dams, planning of restoration activities at the local quarries and construction sites, environmental effects during possible detonation activities, transportation of materials from quarries to the dam sites (specially in the case

10 of Neikovtsi dam located partially in a protected area), impacts from project related access roads, measures taken against erosion and risks from earthquakes and floods. Disclosure of final EIA documents for all three dam investments took place in country and at the Infoshop on May 12, B. Disclosure Requirements Date Environmental Assessment/Audit/Management Plan/Other: Was the document disclosed prior to appraisal? Date of receipt by the Bank 05/07/2009 Date of "in-country" disclosure 05/12/2009 Date of submission to InfoShop 05/12/2009 For category A projects, date of distributing the Executive 05/12/2009 Summary of the EA to the Executive Directors Resettlement Action Plan/Framework/Policy Process: Was the document disclosed prior to appraisal? Date of receipt by the Bank 02/27/2009 Date of "in-country" disclosure 03/24/2009 Date of submission to InfoShop 03/31/2009 Indigenous Peoples Plan/Planning Framework: Was the document disclosed prior to appraisal? Date of receipt by the Bank Date of "in-country" disclosure Date of submission to InfoShop Pest Management Plan: Was the document disclosed prior to appraisal? Date of receipt by the Bank Date of "in-country" disclosure Date of submission to InfoShop * If the project triggers the Pest Management and/or Physical Cultural Resources, the respective issues are to be addressed and disclosed as part of the Environmental Assessment/Audit/or EMP. If in-country disclosure of any of the above documents is not expected, please explain why: C. Compliance Monitoring Indicators at the Corporate Level (to be filled in when the ISDS is finalized by the project decision meeting) OP/BP/GP Environment Assessment Does the project require a stand-alone EA (including EMP) report? If yes, then did the Regional Environment Unit or Sector Manager (SM) review and approve the EA report? Are the cost and the accountabilities for the EMP incorporated in the

11 credit/loan? OP/BP Natural Habitats Would the project result in any significant conversion or degradation of critical natural habitats? If the project would result in significant conversion or degradation of other (non-critical) natural habitats, does the project include mitigation measures acceptable to the Bank? OP/BP Involuntary Resettlement Has a resettlement plan/abbreviated plan/policy framework/process framework (as appropriate) been prepared? If yes, then did the Regional unit responsible for safeguards or Sector Manager review the plan? OP/BP Safety of Dams Have dam safety plans been prepared? Have the TORs as well as composition for the independent Panel of Experts (POE) been reviewed and approved by the Bank? Has an Emergency Preparedness Plan (EPP) been prepared and arrangements been made for public awareness and training? OP Projects on International Waterways Have the other riparians been notified of the project? If the project falls under one of the exceptions to the notification requirement, has this been cleared with the Legal Department, and the memo to the RVP prepared and sent? Has the RVP approved such an exception? The World Bank Policy on Disclosure of Information Have relevant safeguard policies documents been sent to the World Bank s Infoshop? Have relevant documents been disclosed in-country in a public place in a form and language that are understandable and accessible to project-affected groups and local NGOs? All Safeguard Policies Have satisfactory calendar, budget and clear institutional responsibilities been prepared for the implementation of measures related to safeguard policies? Have costs related to safeguard policy measures been included in the project cost? Does the Monitoring and Evaluation system of the project include the monitoring of safeguard impacts and measures related to safeguard policies? Have satisfactory implementation arrangements been agreed with the borrower and the same been adequately reflected in the project legal documents? No N/A No No N/A N/A

12 D. Approvals Signed and submitted by: Name Date Task Team Leader: Mr Gabriel Ionita 05/13/2009 Environmental Specialist: Ms Ruxandra Maria Floroiu 05/13/2009 Social Development Specialist Ms Radhika Srinivasan 03/30/2009 Additional Environmental and/or Social Development Specialist(s): Approved by: Regional Safeguards Coordinator: Ms Agnes I. Kiss 05/18/2009 Comments: Sector Manager: Mr Jonathan S. Kamkwalala 05/18/2009 Comments: