1

Republic of LebanonMinistry of Social Affairs

ENVIRONMENTAL AND SOCIAL ASSESSMENT FRAMEWORK (ESAF)

Social Promotion and Protection Project

January 2013

E4123 v1

2

LIST OF ACRONYMS AND ABRIVIATIONS

SPPP Social Promotion amp Protection ProjectMOSA Ministry of Social AffairsCDD Community Driven DevelopmentCSD Community Social DevelopmentCSO Civil Society Organizations

ESMP Environmental and Social Management PlanESAF Environmental amp Social Assessment FrameworkIGA Income Generation ActivitiesOM Operation ManualPCT Project Coordinating TeamSDC Social Development CentersEIA Environmental Impact AssessmentIA Implementing Agency

LCP Local Community PlatformMOE Ministry of Environment

ES Environmental Specialist

3

TABLE OF CONTENTSList of Acronyms and abbreviations

EXECUTIVE SUMMARY 5

1 INTRODUCTION11 Background 712 Implementation 11

a Institutional amp Implementation Arrangements 11b Purpose of the Environmental Social Assessment Framework (ESAF) 12

2 POLICY LEGAL ADMINISTRATIVE amp ENVIRONMENTAL FRAMEWORK

21 Regulatory Framework for Environmental Impact Assessment 1422 Existing Environmental Legislations 14

221 International Conventions 14222 Existing Lebanese Legislations 15

23 Permit procedures 16

3 POTENTIAL SIGNIFICANT ENVIRONMENTAL IMPACTS ampMITIGATION PROCEDURES

31 Positive Environmental Impact 16311 Consultation amp Public Disclosure 16312 Future Capacity Building Initiatives 17

32 Negative Environmental Impact amp Mitigation Measures 17

4 IMPLEMENTATION ARRANGEMENTS41 Environmental Guidelines 1842 Environmental Assessment 18

5 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)51 Objectives amp Structure of the ESMP 1952 Implementation of Mitigation Measures 1953 Training Program amp Capacity Building 2054 Environmental Monitoring 2355 Sub-project Cycle 2456 Screening of Sub-projects 2457 Environmental amp Social Screening Process 25

571 Sub-project Screening Procedures 25572 Environmental Sub-project Screening Checklist 25

4

573 Assign Environmental Categories 28574 Carrying Out Environmental Work 28575 Review and Approval 28576 Monitoring and Follow Up 29577 Monitoring Indicators 29

58 Staffing amp Capacities of MOSA in Environmental Safeguards 29

6 ENVIRONMENTAL REVIEW PROCEDURES amp GUIDELINES61 Status of the SPPP Environmental Review 3262 Institutional Arrangement 3263 Program Cycle 3364 Promotion of sub-projects 3465 Formulation of Sub-projects 3466 Appraisal amp Approval of Proposed Programs 3567 Implementation amp Monitoring 35

ANNEXES

ANNEX I PRIMARY OBJECTIVES OF MITIGATION MEASURES 36ANNEX II ENVIRONMENTAL FRAMEWORK IN LEBANON 37ANNEXIII TERMS OF REFERENCE FOR THE PREPARATION OF THE

ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)43

Table 1 ESMP TEMPLATES (MITIGATION MEASURES) 47Table 2 ESMP TEMPLATES (TRAINING amp CAPACITY BUILDING) 48Table 3 ESMP TEMPLATES (MONITORING) 49

ANNEX IV PUBLIC CONSULTATION 50

5

EXECUTIVE SUMMARY

This Report has been prepared to present the environmental requirements and guidelines for the Social Promotion and Protection Project (SPPP) that the Government of Lebanon is planning to initiate through the Ministry of Social Affairs (MOSA)

Project DescriptionThe project consists of three components (i) developing the role and capacity of Social Development Centers (SDCs) (ii) establishing and supporting an effective national program in MOSA to finance community developed and driven projects and (iii) continued roll-out and institutionalization of the National Poverty Targeting Program (NPTP)

This Environmental Social Assessment Framework (ESAF) is designed to ensure protection of the health and livelihood of beneficiaries and the environment The framework is intended to protect against both local impacts of individual subprojects and the cumulative impact of many similar subprojects in the same area

Many subprojects have little or no adverse impact However it is important to acknowledge possible unfavorable effects Experience shows that CDD projects need to establish simple social and environmental assessment procedures to avoid causing adverse harm to human health and the environment

The main elements of the Environmental Social Assessment Framework are (1) Tools These tools usually include guidance written in the local language and presented in a form easily understood by community facilitators (2)Implementation Arrangements A description of roles and responsibilities to ensure that the identification avoidance and mitigation of environmental and social risks should be built into sub-project preparation appraisal and supervision (3) Capacity Building Training must be provided to ensure that every person with a role in the safeguard implementation arrangements is able to fulfill their responsibilities (4) Supervision and Monitoring Arrangements should be in place to supervise both the adequacy and application of the safeguard management tools (5) Audit During preparation of the program it is useful to agree that an independent audit of the Safeguards Management Framework will be undertaken at mid-term to draw lessons and recommend improvements

The implementation of the SPPP falls under the responsibility of MOSA who would be in charge of coordinating the various activities through its Social Development Centers (SDC) with concerned local governments and NGOs A Project Coordination Team (PCT) will be established and would comprise experts with relevant experience in implementing similar projects and with proven capacity to handle all functions required in such a project Among its mandates the PCT will ensure that any sponsored subproject is environmentally sound and sustainableThe World Bank Operational Policy (OP 401) on Environmental Assessment (January 1999) defines the Bankrsquos environmental assessment requirements to ensure that funded projects are

6

environmentally sound and sustainable A screening process is undertaken for all funded projects to assess the magnitude and adversity of predicted environmental impacts and to determine the appropriate extent and type of EA Depending on the type location sensitivity and scale of the project as well as the nature and magnitude of environmental impacts projects are classified into one of three categories

(a)- Category A Projects that are likely to cause significant and possibly irremediable environmental impacts

(b)- Category B Projects that might cause lesser adverse impacts than those of Category A and the impacts are often remediable or mitigable

(c)- Category C Projects which could have minimal or no adverse environmental impacts

Subprojects funded by the SPPP are classified as Category B or Category C Sub-projects found to be category A as per World Bank environmental safeguards classification will not be funded by the project

Following this division sub-projects falling only under categories B will need Environmental and Social Management Plans (ESMPs) to be prepared and reviewed for clearance prior to providing final approval for the sub-project

This document describes the needed step and tools that need to be looked at in the design of the sub-project as well as the mitigation measures needed for implementation that takes into account all environmental and social considerations and thus mitigates for any negative impacts in this regard

7

1 INTRODUCTION

11 Background

This document constitutes an integral part of the Project Appraisal Document intended for a World Bank loan to the Government of Lebanon at a total value of USD 30 Million for the implementation of the Social Promotion and Protection Project (SPPP) It has been prepared to present the environmental requirements and guidelines for the SPPP that the Government of Lebanon is planning to initiate through the Ministry of Social Affairs (MOSA)

PROJECT DEVELOPMENT OBJECTIVES

A Project Development Objective

1 The development objective of SPPP is to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

Project Beneficiaries

2 The SPPP beneficiaries consist of the following three categories

(a) Poor and Vulnerable Households and Community Members The ultimate beneficiaries of the project include (a) vulnerable individuals and households (eg children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) who will have improved access to social services provided by SDCs (b) poor and vulnerable individuals who will receive assistance through income generating activities (IGAs) as well as others in the community who will find new employment or experience increased earnings stimulated by growth of IGAs and (c) the poor households who will be eligible to receive NPTP benefits

(b) MOSA The project will help strengthen MOSArsquos capacity to carry out its official mandate both at the central level and through the SDCs at the local levels In particular MOSA will be supported in managing the implementation of small projects using a community-based demand-driven and participatory approach so as to position itself as the main government actor for community development activities in the social sphere At the same time the continued implementation of the NPTP will help MOSA develop the skills needed for administering well-targeted and efficient social safety nets

(c) Civil Society Organizations (CSOs) CSOs will also benefit from the project as they will have an opportunity to improve their capacity to propose prepare and implement income-generating projects and social services at the community level

8

B Project Components

3 The SPPP will have the following four components (1) Social Development Centers (SDCs) (2) Community Social Development Program (CSD) (3) National Poverty Targeting Program (NPTP) and (4) Project Coordination Team (PCT) Component 1 which focuses on building the capacity of the SDCs is cross-cutting between Components 2 and 3 as the SDCs are the local implementing arms of MOSArsquos mandate Specifically both the CSD and NPTP programs rely on the SDCs for implementation

Component 1 Social Development Centers (SDCs) (US$952 million total cost of which US$908 million to be financed from the loan)

4 The objective of this component is to enhance the administrative and operational capacity of the SDCs to enable them to offer social services of improved quality and relevance This component will also include key cross-component functions such as monitoring and evaluation social accountability measures and communication outreach To achieve the above this component will consist of the following sub-components

(a) Equipping automating and electronically linking the SDCs to the central unit at MOSA The project will finance (i) necessary equipment and software to computerize systems and processes at the SDCs (eg creating databases) and to ensure proper processing of NPTP transactions (ii) the establishment of a computerized modular MIS with dedicated modules for the CSD and NPTP1 programs as well as for other core functions (eg procurement financial management) and accessible to both SDCs and the central MOSA unit (iii) internet connectivity between the SDCs and MOSA and (iv) small works and equipment to refurbish and rehabilitate the SDCs as needed

(b) Building and empowering the human resources of the SDCs The project will finance training of SDC staff including in (i) the use of new equipment and systems (ii) specific topics to support the implementation of the CSD and NPTP programs such as handling grievances writing proposals and applying case management and participatory approaches

(c) Community participation The project will finance capacity building and technical assistance for SDCs to (i) establish mechanisms at the SDC level to facilitate community consultation in the SDC catchment area in the form of ldquoLocal Consultative Platformsrdquo (LCP) and (ii) create inventories of local social service providers carry out social needs assessments and prioritization and establish referral systems to ensure that social services match community needs

(d) Monitoring and Evaluation Social Audits and Communication Outreach (see Section IV B for further details) The project will finance the development of a comprehensive MampE system relying primarily on the computerized MIS as well as training of MOSA staff and the project team to use it This will include assessing the performance of the present NPTP MampE system improving it as needed and

1 As an NPTP module is already in use any needed upgrading will be handled under the NPTP Component

9

carrying out short surveys on a regular basis (eg opinion polls) As part of the monitoring effort as well as to promote good governance this component will finance social audits Communication outreach campaigns for the NPTP and the CSD programs will also be supported

Component 2 Community Social Development Program (CSD) (US$1729 million total cost of which US$1232 million to be financed from the loan)

5 This component aims to establish a transparent accountable and efficient national CSD program that will finance community-based sub-projects through grants The CSD program is designed building on the experience of the World Bank-supported Community Development Project (2001-2008) MOSA experiences as well as lessons learnt from other CDD programs in Lebanon and around the world Grant sizes are limited to US$50000 equivalent implementation time for each sub-grant is one year and beneficiaries will be required to make contributions upfront Targeting will be done according to two criteria (a) geographic targeting to prioritize areas of greater poverty and deprivation (eg Akkar district) based on information from updated poverty estimates and studies carried out by various donors (eg the European Union) and (b) categorical targeting to prioritize vulnerable groups (eg the handicapped) based on MOSArsquos mandate The component will consist of the following two sub-components

(a) Establishment of a National Community Social Development Program in MOSA the project will finance technical assistance in the form of key experts (eg CSD program manager engineer social specialist income-generating specialist) who will manage a transparent process of calls for proposals screening and prioritization of proposals and monitoring and supervision of sub-grant implementation

(b) Funding community-driven sub-projects The project will provide grants to eligible applicants (primarily SDCs and CSO) whose projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

10

Component 3 National Poverty Targeting Program (NPTP) (US$17286 million total cost of which US$665 million to be financed from the loan)

6 This component aims to expand the coverage from approximately 100300 (expected in 2013 baseline of SPPP) to 238700 (in 2018) individual beneficiaries as well as to improve the efficiency of the NPTP To achieve this objective the project will provide technical support for the continued roll-out and institutionalization of the NPTP which was launched in 2011 under the Bank-financed Second Emergency Social Protection Implementation Support Project (ESPISP II) Presently NPTP benefits consist of waived school and hospitalization fees coverage of chronic disease medications free schoolbooks and discounts on electricity bills The cost of these benefits as well as that of the SDC social workers involved in administering the program are being borne and will continue to be borne by the Government2 To achieve its objective this component will consist of the following three sub-components

(a) Continued roll-out and institutionalization The project will finance technical assistance for (i) supporting the program management team (ii) refining the program application forms and Proxy-Mean Testing (PMT) questionnaire (iii) upgrading the MIS module for the NPTP and establishing an archiving system (iv) adopting measures to prevent and discourage fraud and corruption (v) refining the grievance and redress mechanism for improved efficiency and transparency

(b) Access to social safety nets The project will finance technical assistance for (i) assessing the performance of the reimbursement mechanism of the NPTP benefits and designing any improvements and (ii) designing and piloting a case management approach with NPTP beneficiary households

(c) Enabling evidence-based policy making for poverty reduction The project will finance (i) technical assistance to support the Inter-ministerial Committee for Social Policy (Social-IMC) and its Secretariat (ii) technical assistance to establish a Poverty Analysis Team whose role will be to assess the poverty and inequality situation in Lebanon using Household Budget Survey (HBS) data and (iii) the design and implementation of the next HBS (in 2017) which will be a large-sample survey representative at the governorate (mohafazat) level

Component 4 Project Coordination Team (PCT) (US$214 million out of which US$195 from the loan)

7 The project will finance a team who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components (see Section III and Annex IV of the Project Appraisal Document) reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively

2 The Council of Ministers allocated US$28 million in 2011 to finance the benefits and approximately US$4 million for the hiring of 350 social workers

11

contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management

12 IMPLEMENTATION

a Institutional and Implementation Arrangements

8 MOSA is the project implementing agency and it will oversee the implementation of all SPPP activities A Project Coordinator will head the PCT and also be responsible for the implementation of Component 1 assisted by a Project Officer while Components 2 and 3 will each be headed by a Program Manager These positions will be financed by project funds A combination of contracted and MOSA staff will be responsible for the implementation of component activities

9 Each component will be overseen by a MOSA committee that will report to the Minister In the case of Components 2 and 3 the committee will be an ldquoEmanating Project Committeerdquo3 which will check the legal aspect of all activities financed and implemented by the component (which is considered an ldquoemanating projectrdquo) and oversee the way the funds are being spent In the case of Component 1 the committee will be a SDC Committee consisting of the SDC Director and other MOSA staff4

10 The heads of the components and the MOSA Minister (as well as the Director General if the position is filled) will form the SPPP Steering Committee which will meet periodically to review implementation progress and ensure coherence with ministry policies At the national policy level the Social Inter-Ministerial Committee (Social-IMC) with MOSA acting as its Technical Secretariat will ensure coordination of the SPPP with other social policies5 Further details are provided in Annex 3 of the Loan Agreement

11 With respect to the institutional setup of the NPTP the program has been operating under a ldquodual managementrdquo by MOSA and the Presidency of the Council of Ministers (PCM)6 This was deemed the best option at the time of appraisal of the ESPISP II project which supported the

3Emanating Project Committees are established as a way to circumvent the cumbersome Lebanese bureaucracy while still providing appropriate oversight They generally comprise five or six members taken from high-ranking positions within the Ministry (eg Department Directors)4 Each SDC has its own Emanating Committee so it would not be possible to also have an Emanating Committee overseeing the component5The Social-IMC established on January 22 2007 by a decree signed by the Prime Minister and composed of the Ministers of Finance Social Affairs Health Education Labor Interior amp Municipal Affairs Economy amp Trade NSSF and the President of CDR is charged with (i) drafting a comprehensive integrated and coordinated social strategy (ii) coordinating government activities for the provisions of social services (iii) ensuring coordination of all studies surveys reports related to social affairs and ensuring availability of relevant social data and indicators (iv) overseeing the implementation of social safety net programs and (v) coordinating monitoring and evaluating development programs that are financed by local and international partners6 This dual management consists of a central management unit at the PCM and Management central unit in MOSA The former is responsible for (i) co-managing the central NPTP database (ii) validating data and cross-checking with national databases (iii) processing household data and generating scores and ranks according to the proxy-means testing (PMT) formula (iv) maintaining the PMT formula (v) analyzing national data and reporting findings to the Social Inter-Ministerial Committee (Social-IMC) (vi) monitoring the NPTP targeting and (vii) auditing data processing The central unit in MOSA (through its SDCs)is responsible for (i) co-managing the central NPTP database (ii) receiving household applications (iii) interfacing with applicants (iv) entering data (v) conducting household visits (vi) checking for data errors (vii) transmitting data to the central database of the NPTP CMU and (viii) managing the public relations campaign

12

creation of the NPTP7 The present institutional setup will be retained during the implementation of the SPPP though the GOL has started discussing the possibility of consolidating the NPTP under MOSA and institutionalizing it as an independent program with its own budgetary allocations

This document is intended to look at designing the Environmental and Social Assessment Framework (ESAF) for the sub-projects to be financed under Component 2 of the SPPP

b Purpose of the Environmental and Social Assessment Framework (ESAF)

12 The ESAF is designed to ensure protection of the health and livelihood of beneficiaries and the environment The framework is intended to protect against both local impacts of individual sub-projects and the cumulative impact of many similar subprojects in the same area

13 Although many sub-projects have little or no adverse impact it is important nonetheless to acknowledge the possible unfavorable effects Experience shows that CDD projects need to establish simple social and environmental assessment procedures to avoid causing adverse harm to human health and the environment

14 The main elements of the Environmental and Social Assessment Framework (ESAF)are described below

Tools These tools usually include guidance written in the local language and presented in a form easily understood by community facilitators as well as

(i) rules-based social and environmental criteria establishing basic dorsquos and donrsquots and indicating the permissions and clearances required for common activities and(ii) mitigation guidelines providing practical guidance for the avoidance or mitigation of potential environmental impacts and identifying issues for which more specific expert guidance should be sought

Implementation Arrangements A description of roles and responsibilities to ensure that the identification avoidance and mitigation of environmental and social risks should be built into sub-project preparation appraisal and supervision This normally includes roles at the levels of community facilitators local management and program-wide management These should also be reflected in any Operational Manual that is prepared This description should abide by the rules and regulations issued by the Ministry of Environment

Capacity Building Training must be provided to ensure that every person with a role in the safeguard implementation arrangements is able to fulfill their responsibilities It is important that training in environmental and social safeguards management is incorporated from the very start of the program before the preparation of sub-projects begins

Supervision and Monitoring Arrangements should be in place to supervise both the adequacy and application of the safeguard management tools In addition it is useful to keep track of environmental concerns in program areas so that more specific mitigation measures can be

7Other options were considered at the time and are detailed in the EPP of the ESPISP II

13

designed and opportunities for enhancements can be promoted Secondary information gathering is usually sufficient for this purpose

Audit During preparation of the program it is useful to agree that an independent audit of the ESAF will be undertaken at mid-term to draw lessons and recommend improvements

15 Experience has shown the value of involving environmental organizations particularly those with advocacy expertise in the design of the Environmental and Social Assessment Frameworks and subsequently in the associated capacity building supervision and monitoring This in fact was done through the consultation process as it will be documented in later sections of this document Access to environmental expertise can be facilitated during program implementation through the identification of local professionals with an environmental background who can form a resource pool to be mobilized locally as subprojects require

16 Social funds and CDD programs also provide important opportunities to promote pro-poor reforms in environmental policies particularly those associated with access to natural resources and their management The involvement of national and local environmental specialists can play a valuable role in advancing these agendas

17 A development project mitigation measures (Annex I) encompass all actions taken to eliminate offset or reduce potentially adverse environmental impacts to acceptable levels Such measures are typically associated with the latter stages of project planning although in practice they may occur at any stage throughout the project cycle Normally potential impacts are identified early during the initiation and scoping stages of EA for a project and measures to avoid or minimize impacts are incorporated into the alternatives being considered In this respect some of the most important measures to protect the environment or local communities become integral to the project design and are never reflected within a formal environmental and social management plan (ESMP) For example the environmental and social bases for choosing a preferred location for a project will not necessarily be evident within the ESMP

18 Environmental and Social Management Plans (ESMPs) outline the mitigation monitoring and institutional measures to be taken during sub-project implementation and operation to avoid or control adverse environmental impacts and the actions needed to implement these measures They provide a crucial link between alternative mitigation measures evaluated and described within the EA report and ensuring that such measures are implemented EA reports are essentially planning documents with no legal basis In many cases mitigation measures outlined in EAs are described in illustrative terms or have neither been committed to by the borrower nor reflected in the project design In this regard the ESMP is a basis for negotiation and reaching agreement with borrowers on a sub-projectrsquos key social and environmental performance standards

19 This report aims at providing guidance in identifying environmental assessment needs for the various sub-projects that are funded under Component 2 of the SPPP and might have the potential of inflicting environmental impacts that need to be addressedFunded sub-projects fall under two categories

14

(i) Social Development (a) improving access to specialized social services to satisfy the needs of vulnerable groups at risk including the disabled children youth women and the elderly (b) enhancing environmental protection initiatives such as reforestation and soil erosion control wells and spring protection and preservation of natural sites

(ii) Income Enhancement Capacity building activities to support (a) micro and small entrepreneurs and non-governmental organizations providing credit to target beneficiary groups and (b) women youth and disabled people in order to provide them with demand driven specialized skills to improve their income and enhance their business opportunities

2 POLICY LEGAL amp INSTITUTIONAL FRAMEWORK FOR THE ENVIRONMENT

21 Regulatory Framework for Environmental Impact Assessment

20 Presently the environmental framework of Lebanon is managed and supervised by the Ministry of Environment (MOE) that was created by law 216 of April 2nd 1993 to be the government institution responsible for the development of a national strategy for sustainable development This was strengthened through the Law 4442002 Framework Law for the Protection of the Environment and the CEA (Country Environmental Analysis) The MOE is undergoing several review procedures to up-date the countryrsquos environmental policies and regulations including the preparation of an Environmental Code issuance of an Environmental Impact Assessment (EIA) decree as well as norms and standards for environmental protection The Environmental codes as well as the EIA decree were prepared with the assistance of the World Bank under the Mediterranean Environmental Technical Assistance Program (METAP) Also the World Bank has financed through METAP an assessment of the EIA System in Lebanon (Annex II)

METAP has also supported the establishment of an Environmental Management System Unit (EMSU) dealing with EIA at the MOE The concept of EA as part of project planning in Lebanon is still new and has only recently gained some attention The Environmental Impact Assessment (EIA) decree that was prepared by the MOE will require that an EIA be prepared during the planning process of both public and private development projects in Lebanon

22 Existing Environmental Legislation

221 International Conventions

21 The Lebanese Government has ratified a large number of international conventions for Environmental Protection Among the most important ones are

The Barcelona Convention for the protection of the Mediterranean SEA International Convention on World Heritage Protection International Convention on Bio-diversity Protection United Nations Convention on Desertification Montreal Protocol for the protection of the Ozone layer

15

222 Existing Lebanese Legislations

22 A list of the most significant existing environmental legislation is given in Annex II The primary safeguards as they are likely to affect SPPP subprojects are summarized in the following sections

Natural LandscapeProtection of the natural landscape of Lebanon was first addressed under the Law of January 1949 Recently cutting of trees was severely restricted under Decree No142 of March 1993 and further protection was provided under Law No 550 dated July 1996 There are also a number of Laws and Decisions that were issued to protect sites of particularly valuable landscape by declaring them Natural Reserves

Soil Water and Air PollutionProtection against pollution was first addressed by Decree No 8735 of October 1974 that prohibited the digging of wells for the disposal of raw sewage banned infiltration from cesspools and the use of sewage for the irrigation of vegetables and some fruits Decision No 521 of July 1996 introduced measures to deal with the pollution of the air water and soil including national standards for drinking water bathing waters and wastewater quality Recently Decision No 81 dated March 2001completed and reviewed the previously issued standards

Water ResourcesGround and surface water resources have been protected since the introduction of Order No 144 dated June 1925 which covered the major springs that supply the countryrsquos potable and irrigation needs Zoning of water sources and recharging of catchment areas was introduced by Decree 10276 of October 1962 to cope with increasing demand for water In 1970 Decree 14438 established a limit on the depth and exploitation of unlicensed wells and boreholes 150 m and 100 m3d respectively

Archaeological and Historical SitesThe protection of archaeological and historic sites was first addressed in Law No 1666 of November 1933 Later legislation has been introduced to afford special protection to the Cultural Heritage World Heritage and Cultural Landscape Sites declared by UNESCO

Public StreetsLaw No 60 of September 1983 covers Work in public streets law No 98 of September 1989 and by Circular 695 issued by the Prime Ministerrsquos Office on March 1995

Decree 86332012 on EIA describes clearly the various measures that need to be considered in the preliminary Environmental Evaluation of any project Projects found to require further investigation will have to be subjected to an EIA whereby complete set of information is required to allow for the Ministry to suggest needed mitigation measures and issue accordingly needed permits The stipulations of the decree go in hand with most of the WB guidelines The decree describes the various categories of sub-projects that do

16

require EIA and what are the projects that might cause risks and hazards A copy of the decree will be attached as an Annex to this document

23 Permit Procedures

23 Depending on the type and size of the sub-project to be executed and according to the Lebanese legislation a number of approvals and permits might be required from various governmental agencies In view of their nature and scale the majority of the sub-projects that would be funded by the SPPP will only require the approval of the municipality and or the Ministry of Municipalities and Rural Affairs

3 POTENTIAL SIGNIFICANT ENVIRONMENTAL IMPACTS AND GOOD PRACTICE MITIGATION PROCEDURES

31 Positive Environnemental Impact

24 Most sub-projects financed by the SPPP that are well designed and properly implemented can have a positive impact on the environment The benefits of this type of sub-projects are often long term rather than short term and are not limited to the specific local community Examples of environmentally beneficial sub-projects that will be financed by the SPPP are subject to case by case assessment soil erosion protection protection of natural and cultural heritage sites

a Consultation and Public Disclosure

25 A simple approach is proposed for public consultation in the early stages of sub-project preparation and planning

The stakeholders should be made aware of the different elements and features of each sub-project and their main objectives and target groups Once an ESIA has been made the results of this study should be disclosed to all concerned primary stakeholders

The stakeholders should then be encouraged to share their concerns worries and any comments they have on the sub-project or its likely impacts This should include discussions on alternative and proposed mitigation measures that are to be accounted for in the sub-project design implementation and operation phases

The final step is to incorporate the stakeholder inputs into the sub-project plans in order to improve the sub-project design

26 The process of stakeholder involvement and consultation will continue during sub-project implementation as well in order to integrate any additional comments and worries that may arise from the construction and implementation phase

27 Consultation with the stakeholders may take different forms depending on the need and subject matter that is being communicated An informative method would be through the use of one-way communication techniques such as audio (radio) visual (television) printed (leaflets brochures pictures diagrams posters) or electronic media (internet and electronic mail) In this case the stakeholders will be merely informed with certain information and there shall be no opportunity for questions or comments In order to have interactive consultation with the

17

stakeholders two-way participatory techniques are required This may include one-to-one briefings small group and village meetings and the organization of workshops and forums

28 The technique used for the disclosure and dissemination of information and data should take into consideration stakeholder preferences and characteristics The disclosed information should be in a language that all stakeholders are familiar with and for those who are illiterate certain measures may need to be taken to ensure that they are fully aware of the contents of the disclosed documents Another important consideration is that ample time should be given to the stakeholders to review the disclosed information prior to the consultation process to allow them to thoroughly address the sub-projects various issues

29 The SPPP will also generate environmental benefits through a variety of other mechanisms among which are

(a)- Generation of environmental assessment guidelines that can be used by other organizations or ministries or could be adopted by the Ministry of Environment for more general use

(b)- Training of environmental specialists thus increasing the number of environmental professionals in the country

(c)- Improved environmental awareness in the local communities

b Future capacity building initiatives

30 These could be done through a structured training along two parallel lines (i) at the level of the implementing agencies when these are guided one by one through the process by the environmental specialist to help them look at the needed assessment and the mitigation measures if any (ii) at the level of the community by organizing awareness campaigns targeted to LCP and other prominent figures and other interested CSOs on environmental issues of relevance and how that affects the sub-projects implemented in their areas That creates a social accountability system that could be used to ensure that the sub-projects are implemented according to appropriate procedures

32 Negative Environmental Impacts

321 Overview of Negative Environmental Impacts

31 The SPPP will finance a considerable number of different types of subprojects An important percentage of the funding will be allocated for social development Though intended to improve environmental and social conditions these subprojects can have a variety of negative environmental impacts that might be encountered during the operation of the subprojects Environmental impacts arising from the operation of the different subprojects can be minimized by appropriate site selection good engineering design and appropriate construction techniques

4 IMPLEMENTATION ARRANGEMENTS

41 Environmental Guidelines

18

32 The implementation of the SPPP falls under the responsibility of MOSA who would be in charge of coordinating the various activities through its Social Development Centers (SDCs) with concerned local governments and NGOs A Project Coordination Team (PCT) will be established and would comprise experts with relevant experience in implementing similar projects and with proven capacity to handle all functions required in such a project Among its mandates the PCT will ensure that any sponsored subproject is environmentally sound and sustainable

33 The PCT shall ensure the following

Environmental considerations will be included as criteria for selecting activities to be supported by the project environmental assessment would become an integral part of the project cycle of any subproject

Environmental guidelines are followed and used throughout the project cycle

Environmental issues are introduced to beneficiaries through education and promotion of environmentally beneficial subprojects

34 The execution of the CSD will be undertaken by Civil Society Organizations (CSO) who would consist of qualified local authorities or national NGOs with strong community ties and proven execution capacity The SDC would assist local NGOs LCF and communities in identifying local needs preparing subprojects coordinating with concerned ministries and implementing the subprojects

42 Environmental Assessment (EA)

35 The World Bank Operational Policy (OP 401) on Environmental Assessment (January 1999) defines the Bankrsquos environmental assessment requirements to ensure that funded sub-projects are environmentally sound and sustainable A screening process is undertaken for all funded sub-projects to assess the magnitude and adversity of predicted environmental impacts and to determine the appropriate extent and type of EA Depending on the type location sensitivity and scale of the project as well as the nature and magnitude of environmental impacts sub-projects are classified into one of three categories

(a)- Category A Sub-Projects that are likely to cause significant and possibly irremediable environmental impacts

(b)- Category B Sub-Projects that might cause lesser adverse impacts than those of Category A and the impacts are often remediable or could be mitigated for

(c)- Category C Sub-Projects which could have minimal or no adverse environmental impacts

19

36 The SPPP will only fund sub-projects that can be classified as either Category B or Category C only For instance all income enhancement sub-projects will be classified as Category C while most social sub-projects will be Category B Sub-projects that are likely to cause substantial negative impacts and are expected to fall in Category A will not be approved for funding

37 This document will provide guidance with respect to the preparation of environmental assessment for the various funded subprojects These guidelines are based on the World Bank Operational Policies (OP 401) the Environmental Assessment Source book (1991) and its updates in addition to the Decree 86332012 on EA issued by the GOL

5 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

51 Objectives and Structure of the ESMP

38 The objectives of the ESMP are to mitigate the adverse environmental impacts identified in the SPPP The ESMP will consist of three kinds of activities

o Implementation of mitigation measures o Strengthening the capacities of PCT SDCs and local NGOs o Monitoring and evaluation of mitigation measures identified during subproject

formulation or within the environmental assessment report

52 Implementation of Mitigation Measures

39 Mitigation measures identified (Table 1) are for typical sub-projects and MOSAPCT will ensure that such measures are adhered to during the overall implementation of the SPPP

Table 1 Potential Environmental Impacts and Proposed Mitigation Measures for Different Subprojects

Project Component

Potential Impacts Mitigation Measures Responsibility

Roads rehabilitation

Clogging of natural drainage channelsEncroachment on private property

Dumping of construction wastes and accidental spills of machine fuels etcRisk of damage to unknown archaeological sites

Maintain ditches

Detailed property boundary surveys and flagging in fieldProper disposal of construction wastes

Use ldquochance findrdquo procedures and coordinate with appropriate

Contractor

ContractorIA

Contractor

IAsArcheology department

20

government agency

Rehabilitation of schools

Rehabilitation of health clinics

Irrigation and drainage

Improper disposal of wastes

Water quality degradation in ponds and reservoirsClogging of canals from weedssedimentsInefficient water flow because of heavy sedimentation

Degradation of water systems receiving irrigation waters by nutrients agrochemical and salts

Proper disposal of solid wastesPriority given to rehabilitation of toiletsInstallation of sanitation (cesspools)

Containerize infectious wastesPublic health awareness

Monitoring of water qualityOperation amp maintenance planProper design of canals and provision of access for weed and sediments removal

Control of agrochemical use

IAsMunicipality

IAscommunity

IAscommunity

Ministry of Health

Ministry of Energy and Water

IAs community

ContractorIAs

Ministry of Agriculturecommunity

53 Training Program and Capacity Building

40 The MOSA lacks the capacities and the expertise to work in the field of environmental monitoring and protection Moreover it is expected that the IAs mostly CSOs and SDCs do not have the needed resources to undertake the requirements needed in terms of EAs and designing mitigation measures This would require a detailed capacity building program that targets all levels of the decision making process in the project The central team at the MOSA and the PCT need to be oriented to the general approach to environmental safeguards importance use and how that could affect the selection implementation and monitoring of Sub-projects SDFCs and IAs should be trained on

21

the technical aspects of detection and mitigation and how these could be imbedded within the process of project identification to formulation to implementation These safeguards will have to be an integral part of any sub-project proposal and consequently any detailed action plan for any specific sub-project Environmental expertise within the implementing and executing bodies will be strengthened Training programs will designed and implemented with the assistance of a local or international expert and will target levels as stated in the Table 2 page 20

41 PCT and IAs At the initiation of the CSD and prior to bidding and selection of IAs a workshop will be provided and will include an environmental session to raise environmental awareness and to clarify the specific environmental requirements related to design and implementation of the SPPP

42 Another training workshop will be provided to the PCT and selected IAs and will cover the following to IAs

EIA techniques Screening sub-projects for environmental review Use of practical formschecklists Best environmental practices in design and implementation of projects Effective implementation of mitigation measures Project supervision Monitoring and evaluation

43 Local NGOs and Contractors IAs will be required to provide workshops for local NGOs and contractors focusing on public awareness case studies of environmental issues experienced in similar projects use of environmental guidelines and implementation of mitigation measures (Table 2 Annex III)

22

Table 2 Training and Capacity Building Program for Implementing the ESAFTraining

Capacity BuildingParticipating Stakeholders

Skills acquired Scheduling Cost Source

ManagementInstitutional

1year

SPPP manager MOSA central unit Head of concerned

departments at MOSA PCT

Decision making and delegation Work procedures Environmental awareness National guidelines WB guidelines Classification and mitigation

Prior to sub-project preparation Planning phase Refresher every 3 months as we

go along the project

Undertaken by the Environmental

SpecialistMiscellaneous

7500 USD

WBMOSA

Institutional at Intermediate levels

2 training sessions of 2 days year

(for SDC and IA X5 regions)

PCT Emanating committee SDC managers IAs

Environmental and social policies

Laws and regulations GOL and WB safeguards Evaluation and selection

During sub-project preparation Planning phase Sub-project evaluation

Undertaken by the Environmental

SpecialistMiscellaneous

30000 USD

WB MOSA

Implementation1 day session X2 year X 5 regions

IAs SDC staff Beneficiaries Municipalities

Environment and social tools Screening amp monitoring

methods Sustainability of the process Practical mitigation and

safeguards

During sub-project preparation Mobilization Implementation

Undertaken by the Environmental

SpecialistMiscellaneous

50000 USD

WB MOSA

Monitoring Evaluation and

Reporting1 dayX2 year X5

regions

IAs SDC staff Beneficiaries

Municipalities

Environmental and social monitoring and compliance

Progress report preparation Monitoring and Evaluation

During sub-project preparation MobilizationImplementation

Environmental Specialist + consultant

50000 USD

WB MOSA

Total 137500 USD (includes in kind contribution from MOSA)

23

54 Environmental Monitoring

44 Environmental Monitoring will be the responsibility of the ES PCT and MOSA Central Unit with the supervision of the LCP and will include compliance monitoring during implementation and also monitoring of significant impacts during the operation of the subproject

Table 3 Typical Examples of Monitoring Plan for the Operation of Different Subprojects

Sub-project Monitoring Indicators Responsibility FrequencyRoads rehabilitation

Operating drainage channels

NGOs in close coordination with local community

Semi-annual assessment

Improvements to Water Supply and Sanitation Facilities

Irrigation and drainage

Distribution network without leaksNo leakage or overflows of manholes or drainsWater Quality Monitoring

Irrigation network without leaksDrainage channels clean and properly maintainedWater quality parameters (pH COD BOD SS)

NGOs in close coordination with local community

Ministry of Health and Ministry of Energy and Water

NGOs in close coordination with local community

Testing by Ministry of Health and Ministry of Energy and Water

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Rehabilitation of schools

Rehabilitation of health clinics

Toilet facilities clean and functioning properlyDrinking water faucets clean and safe from contamination

NGOs in close coordination with local community and appropriate municipality

Ministry of Health in close coordination with local community

Semi-annual assessment

Semi-annual assessment

23

24

45 The Environmental Specialist (ES) of the PCT will also conduct periodic monitoring by visiting the sites of the various sub-projects at least twice during the implementation period of the sub-project

46 Monitoring indicators shall be developed for both the mobilization and the operation phase of the subprojects Monitoring of activities will have to ensure that mitigation measures of operations impacts are being implemented properly while the monitoring of operation is to ensure that no unforeseen negative impacts are arising

55 Sub-project Cycle

47 Component 2 of the SPPP is the Community Social Development Program (CSD) which will be financing community-based sub-projects through grants The Program will have two windows one for social services whereas the other is for Income Generation Activities (IGA) support with the review and approval mechanisms in large part being the same for both windows While Component 3 focuses on Poverty Targeting thus the services provided will have no impact on the environment component 1 will focus on the provision of technology and training to SDCs

48 Applicants will be invited to use standard forms (available on the MOSA website and upon request from SDCs) to submit proposals to the relevant SDC in cases where the applicant is the SDC itself the application will be submitted directly to the CSD program team in Beirut

49 SDCs will immediately check all proposals for completeness and give a receipt to the applicant with a proposal number proposals found to be incomplete will be rejected with an explanation All complete proposals will be presented for discussion to the relevant Local Community Platform (LCP) or equivalent consultative body to obtain feedback on among other things the actual need (in case of social services) or likely market value (in the case of IGA) of the proposed activity the reputation of the applicant the likely sustainability of the proposed activity the preliminary classification of the project within environmental categories (the final classification will be pending on the decision of the environmental specialist within the PCT) any problematic aspect (conflict of interest etc) and the overall compliance of the proposal with the purposes of the program This feedback is not binding but will be taken into consideration when deciding whether or not to fund the proposal The CSD program team will carry out a detailed desk review of all complete proposals to assess their technical quality as well as the budget and time line suggested for the sub-project The environmental specialist member of the Project Coordinating Team (PCT) will review the proposal and prepare all needed documentation based on his classification of the sub-project

56 Screening of Sub-Projects

50 Each sub-project to be implemented by an IA will be subjected to an environmental screening Using the screening form (Form 1) environmental and social checklists for the proposed sub-projects will be screened by the environmental specialist to identify any potential adverse impacts

25

From an environmental standpoint the screening form may identify impacts form sub-projects the issue of solid waste disposal at the site of a sub-project may come out as a point to look at in terms of designing mitigation measures to avoid negative impacts The selection of adequate storage collection and proper disposal could be steps to consider carefully

57 The Environmental and Social Screening Process

51 The objectives of sub-project screening is to determine which activities are likely to have negative environmental and social impacts

571 Subproject Screening Procedures

52 The sub-projects funded under this project are generally categorized as Category B or C and screening mechanisms would ensure that any identified Category A sub-projects are not funded under the project Due to the fact that most Category B sub-projects are small-scale which do not result in adverse negative environmental impacts this will require an ESMP which has clear due diligence environmental and social procedures (including the setting out of institutional responsibilities timing and budget) for sub-projects The ESMP should take into consideration the applicable requirements under the Bankrsquos ten safeguard policies

572 Environmental Sub-Project Screening Checklistsforms

53 The Operation Manual (OM) should contain for each type of sub-project a simple environmental screening checklist (Form 1)) which poses a series of questions designed to identify risks to the environment The goal of the checklist (also called a screening or environmental data sheet) is to identify which sub-projects require more environmental information in the form of a site-specific ESMP or which can proceed without any special mitigation measures that is falling under category C

Form 1 Environmental Screening Check-list

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

2

LIST OF ACRONYMS AND ABRIVIATIONS

SPPP Social Promotion amp Protection ProjectMOSA Ministry of Social AffairsCDD Community Driven DevelopmentCSD Community Social DevelopmentCSO Civil Society Organizations

ESMP Environmental and Social Management PlanESAF Environmental amp Social Assessment FrameworkIGA Income Generation ActivitiesOM Operation ManualPCT Project Coordinating TeamSDC Social Development CentersEIA Environmental Impact AssessmentIA Implementing Agency

LCP Local Community PlatformMOE Ministry of Environment

ES Environmental Specialist

3

TABLE OF CONTENTSList of Acronyms and abbreviations

EXECUTIVE SUMMARY 5

1 INTRODUCTION11 Background 712 Implementation 11

a Institutional amp Implementation Arrangements 11b Purpose of the Environmental Social Assessment Framework (ESAF) 12

2 POLICY LEGAL ADMINISTRATIVE amp ENVIRONMENTAL FRAMEWORK

21 Regulatory Framework for Environmental Impact Assessment 1422 Existing Environmental Legislations 14

221 International Conventions 14222 Existing Lebanese Legislations 15

23 Permit procedures 16

3 POTENTIAL SIGNIFICANT ENVIRONMENTAL IMPACTS ampMITIGATION PROCEDURES

31 Positive Environmental Impact 16311 Consultation amp Public Disclosure 16312 Future Capacity Building Initiatives 17

32 Negative Environmental Impact amp Mitigation Measures 17

4 IMPLEMENTATION ARRANGEMENTS41 Environmental Guidelines 1842 Environmental Assessment 18

5 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)51 Objectives amp Structure of the ESMP 1952 Implementation of Mitigation Measures 1953 Training Program amp Capacity Building 2054 Environmental Monitoring 2355 Sub-project Cycle 2456 Screening of Sub-projects 2457 Environmental amp Social Screening Process 25

571 Sub-project Screening Procedures 25572 Environmental Sub-project Screening Checklist 25

4

573 Assign Environmental Categories 28574 Carrying Out Environmental Work 28575 Review and Approval 28576 Monitoring and Follow Up 29577 Monitoring Indicators 29

58 Staffing amp Capacities of MOSA in Environmental Safeguards 29

6 ENVIRONMENTAL REVIEW PROCEDURES amp GUIDELINES61 Status of the SPPP Environmental Review 3262 Institutional Arrangement 3263 Program Cycle 3364 Promotion of sub-projects 3465 Formulation of Sub-projects 3466 Appraisal amp Approval of Proposed Programs 3567 Implementation amp Monitoring 35

ANNEXES

ANNEX I PRIMARY OBJECTIVES OF MITIGATION MEASURES 36ANNEX II ENVIRONMENTAL FRAMEWORK IN LEBANON 37ANNEXIII TERMS OF REFERENCE FOR THE PREPARATION OF THE

ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)43

Table 1 ESMP TEMPLATES (MITIGATION MEASURES) 47Table 2 ESMP TEMPLATES (TRAINING amp CAPACITY BUILDING) 48Table 3 ESMP TEMPLATES (MONITORING) 49

ANNEX IV PUBLIC CONSULTATION 50

5

EXECUTIVE SUMMARY

This Report has been prepared to present the environmental requirements and guidelines for the Social Promotion and Protection Project (SPPP) that the Government of Lebanon is planning to initiate through the Ministry of Social Affairs (MOSA)

Project DescriptionThe project consists of three components (i) developing the role and capacity of Social Development Centers (SDCs) (ii) establishing and supporting an effective national program in MOSA to finance community developed and driven projects and (iii) continued roll-out and institutionalization of the National Poverty Targeting Program (NPTP)

This Environmental Social Assessment Framework (ESAF) is designed to ensure protection of the health and livelihood of beneficiaries and the environment The framework is intended to protect against both local impacts of individual subprojects and the cumulative impact of many similar subprojects in the same area

Many subprojects have little or no adverse impact However it is important to acknowledge possible unfavorable effects Experience shows that CDD projects need to establish simple social and environmental assessment procedures to avoid causing adverse harm to human health and the environment

The main elements of the Environmental Social Assessment Framework are (1) Tools These tools usually include guidance written in the local language and presented in a form easily understood by community facilitators (2)Implementation Arrangements A description of roles and responsibilities to ensure that the identification avoidance and mitigation of environmental and social risks should be built into sub-project preparation appraisal and supervision (3) Capacity Building Training must be provided to ensure that every person with a role in the safeguard implementation arrangements is able to fulfill their responsibilities (4) Supervision and Monitoring Arrangements should be in place to supervise both the adequacy and application of the safeguard management tools (5) Audit During preparation of the program it is useful to agree that an independent audit of the Safeguards Management Framework will be undertaken at mid-term to draw lessons and recommend improvements

The implementation of the SPPP falls under the responsibility of MOSA who would be in charge of coordinating the various activities through its Social Development Centers (SDC) with concerned local governments and NGOs A Project Coordination Team (PCT) will be established and would comprise experts with relevant experience in implementing similar projects and with proven capacity to handle all functions required in such a project Among its mandates the PCT will ensure that any sponsored subproject is environmentally sound and sustainableThe World Bank Operational Policy (OP 401) on Environmental Assessment (January 1999) defines the Bankrsquos environmental assessment requirements to ensure that funded projects are

6

environmentally sound and sustainable A screening process is undertaken for all funded projects to assess the magnitude and adversity of predicted environmental impacts and to determine the appropriate extent and type of EA Depending on the type location sensitivity and scale of the project as well as the nature and magnitude of environmental impacts projects are classified into one of three categories

(a)- Category A Projects that are likely to cause significant and possibly irremediable environmental impacts

(b)- Category B Projects that might cause lesser adverse impacts than those of Category A and the impacts are often remediable or mitigable

(c)- Category C Projects which could have minimal or no adverse environmental impacts

Subprojects funded by the SPPP are classified as Category B or Category C Sub-projects found to be category A as per World Bank environmental safeguards classification will not be funded by the project

Following this division sub-projects falling only under categories B will need Environmental and Social Management Plans (ESMPs) to be prepared and reviewed for clearance prior to providing final approval for the sub-project

This document describes the needed step and tools that need to be looked at in the design of the sub-project as well as the mitigation measures needed for implementation that takes into account all environmental and social considerations and thus mitigates for any negative impacts in this regard

7

1 INTRODUCTION

11 Background

This document constitutes an integral part of the Project Appraisal Document intended for a World Bank loan to the Government of Lebanon at a total value of USD 30 Million for the implementation of the Social Promotion and Protection Project (SPPP) It has been prepared to present the environmental requirements and guidelines for the SPPP that the Government of Lebanon is planning to initiate through the Ministry of Social Affairs (MOSA)

PROJECT DEVELOPMENT OBJECTIVES

A Project Development Objective

1 The development objective of SPPP is to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

Project Beneficiaries

2 The SPPP beneficiaries consist of the following three categories

(a) Poor and Vulnerable Households and Community Members The ultimate beneficiaries of the project include (a) vulnerable individuals and households (eg children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) who will have improved access to social services provided by SDCs (b) poor and vulnerable individuals who will receive assistance through income generating activities (IGAs) as well as others in the community who will find new employment or experience increased earnings stimulated by growth of IGAs and (c) the poor households who will be eligible to receive NPTP benefits

(b) MOSA The project will help strengthen MOSArsquos capacity to carry out its official mandate both at the central level and through the SDCs at the local levels In particular MOSA will be supported in managing the implementation of small projects using a community-based demand-driven and participatory approach so as to position itself as the main government actor for community development activities in the social sphere At the same time the continued implementation of the NPTP will help MOSA develop the skills needed for administering well-targeted and efficient social safety nets

(c) Civil Society Organizations (CSOs) CSOs will also benefit from the project as they will have an opportunity to improve their capacity to propose prepare and implement income-generating projects and social services at the community level

8

B Project Components

3 The SPPP will have the following four components (1) Social Development Centers (SDCs) (2) Community Social Development Program (CSD) (3) National Poverty Targeting Program (NPTP) and (4) Project Coordination Team (PCT) Component 1 which focuses on building the capacity of the SDCs is cross-cutting between Components 2 and 3 as the SDCs are the local implementing arms of MOSArsquos mandate Specifically both the CSD and NPTP programs rely on the SDCs for implementation

Component 1 Social Development Centers (SDCs) (US$952 million total cost of which US$908 million to be financed from the loan)

4 The objective of this component is to enhance the administrative and operational capacity of the SDCs to enable them to offer social services of improved quality and relevance This component will also include key cross-component functions such as monitoring and evaluation social accountability measures and communication outreach To achieve the above this component will consist of the following sub-components

(a) Equipping automating and electronically linking the SDCs to the central unit at MOSA The project will finance (i) necessary equipment and software to computerize systems and processes at the SDCs (eg creating databases) and to ensure proper processing of NPTP transactions (ii) the establishment of a computerized modular MIS with dedicated modules for the CSD and NPTP1 programs as well as for other core functions (eg procurement financial management) and accessible to both SDCs and the central MOSA unit (iii) internet connectivity between the SDCs and MOSA and (iv) small works and equipment to refurbish and rehabilitate the SDCs as needed

(b) Building and empowering the human resources of the SDCs The project will finance training of SDC staff including in (i) the use of new equipment and systems (ii) specific topics to support the implementation of the CSD and NPTP programs such as handling grievances writing proposals and applying case management and participatory approaches

(c) Community participation The project will finance capacity building and technical assistance for SDCs to (i) establish mechanisms at the SDC level to facilitate community consultation in the SDC catchment area in the form of ldquoLocal Consultative Platformsrdquo (LCP) and (ii) create inventories of local social service providers carry out social needs assessments and prioritization and establish referral systems to ensure that social services match community needs

(d) Monitoring and Evaluation Social Audits and Communication Outreach (see Section IV B for further details) The project will finance the development of a comprehensive MampE system relying primarily on the computerized MIS as well as training of MOSA staff and the project team to use it This will include assessing the performance of the present NPTP MampE system improving it as needed and

1 As an NPTP module is already in use any needed upgrading will be handled under the NPTP Component

9

carrying out short surveys on a regular basis (eg opinion polls) As part of the monitoring effort as well as to promote good governance this component will finance social audits Communication outreach campaigns for the NPTP and the CSD programs will also be supported

Component 2 Community Social Development Program (CSD) (US$1729 million total cost of which US$1232 million to be financed from the loan)

5 This component aims to establish a transparent accountable and efficient national CSD program that will finance community-based sub-projects through grants The CSD program is designed building on the experience of the World Bank-supported Community Development Project (2001-2008) MOSA experiences as well as lessons learnt from other CDD programs in Lebanon and around the world Grant sizes are limited to US$50000 equivalent implementation time for each sub-grant is one year and beneficiaries will be required to make contributions upfront Targeting will be done according to two criteria (a) geographic targeting to prioritize areas of greater poverty and deprivation (eg Akkar district) based on information from updated poverty estimates and studies carried out by various donors (eg the European Union) and (b) categorical targeting to prioritize vulnerable groups (eg the handicapped) based on MOSArsquos mandate The component will consist of the following two sub-components

(a) Establishment of a National Community Social Development Program in MOSA the project will finance technical assistance in the form of key experts (eg CSD program manager engineer social specialist income-generating specialist) who will manage a transparent process of calls for proposals screening and prioritization of proposals and monitoring and supervision of sub-grant implementation

(b) Funding community-driven sub-projects The project will provide grants to eligible applicants (primarily SDCs and CSO) whose projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

10

Component 3 National Poverty Targeting Program (NPTP) (US$17286 million total cost of which US$665 million to be financed from the loan)

6 This component aims to expand the coverage from approximately 100300 (expected in 2013 baseline of SPPP) to 238700 (in 2018) individual beneficiaries as well as to improve the efficiency of the NPTP To achieve this objective the project will provide technical support for the continued roll-out and institutionalization of the NPTP which was launched in 2011 under the Bank-financed Second Emergency Social Protection Implementation Support Project (ESPISP II) Presently NPTP benefits consist of waived school and hospitalization fees coverage of chronic disease medications free schoolbooks and discounts on electricity bills The cost of these benefits as well as that of the SDC social workers involved in administering the program are being borne and will continue to be borne by the Government2 To achieve its objective this component will consist of the following three sub-components

(a) Continued roll-out and institutionalization The project will finance technical assistance for (i) supporting the program management team (ii) refining the program application forms and Proxy-Mean Testing (PMT) questionnaire (iii) upgrading the MIS module for the NPTP and establishing an archiving system (iv) adopting measures to prevent and discourage fraud and corruption (v) refining the grievance and redress mechanism for improved efficiency and transparency

(b) Access to social safety nets The project will finance technical assistance for (i) assessing the performance of the reimbursement mechanism of the NPTP benefits and designing any improvements and (ii) designing and piloting a case management approach with NPTP beneficiary households

(c) Enabling evidence-based policy making for poverty reduction The project will finance (i) technical assistance to support the Inter-ministerial Committee for Social Policy (Social-IMC) and its Secretariat (ii) technical assistance to establish a Poverty Analysis Team whose role will be to assess the poverty and inequality situation in Lebanon using Household Budget Survey (HBS) data and (iii) the design and implementation of the next HBS (in 2017) which will be a large-sample survey representative at the governorate (mohafazat) level

Component 4 Project Coordination Team (PCT) (US$214 million out of which US$195 from the loan)

7 The project will finance a team who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components (see Section III and Annex IV of the Project Appraisal Document) reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively

2 The Council of Ministers allocated US$28 million in 2011 to finance the benefits and approximately US$4 million for the hiring of 350 social workers

11

contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management

12 IMPLEMENTATION

a Institutional and Implementation Arrangements

8 MOSA is the project implementing agency and it will oversee the implementation of all SPPP activities A Project Coordinator will head the PCT and also be responsible for the implementation of Component 1 assisted by a Project Officer while Components 2 and 3 will each be headed by a Program Manager These positions will be financed by project funds A combination of contracted and MOSA staff will be responsible for the implementation of component activities

9 Each component will be overseen by a MOSA committee that will report to the Minister In the case of Components 2 and 3 the committee will be an ldquoEmanating Project Committeerdquo3 which will check the legal aspect of all activities financed and implemented by the component (which is considered an ldquoemanating projectrdquo) and oversee the way the funds are being spent In the case of Component 1 the committee will be a SDC Committee consisting of the SDC Director and other MOSA staff4

10 The heads of the components and the MOSA Minister (as well as the Director General if the position is filled) will form the SPPP Steering Committee which will meet periodically to review implementation progress and ensure coherence with ministry policies At the national policy level the Social Inter-Ministerial Committee (Social-IMC) with MOSA acting as its Technical Secretariat will ensure coordination of the SPPP with other social policies5 Further details are provided in Annex 3 of the Loan Agreement

11 With respect to the institutional setup of the NPTP the program has been operating under a ldquodual managementrdquo by MOSA and the Presidency of the Council of Ministers (PCM)6 This was deemed the best option at the time of appraisal of the ESPISP II project which supported the

3Emanating Project Committees are established as a way to circumvent the cumbersome Lebanese bureaucracy while still providing appropriate oversight They generally comprise five or six members taken from high-ranking positions within the Ministry (eg Department Directors)4 Each SDC has its own Emanating Committee so it would not be possible to also have an Emanating Committee overseeing the component5The Social-IMC established on January 22 2007 by a decree signed by the Prime Minister and composed of the Ministers of Finance Social Affairs Health Education Labor Interior amp Municipal Affairs Economy amp Trade NSSF and the President of CDR is charged with (i) drafting a comprehensive integrated and coordinated social strategy (ii) coordinating government activities for the provisions of social services (iii) ensuring coordination of all studies surveys reports related to social affairs and ensuring availability of relevant social data and indicators (iv) overseeing the implementation of social safety net programs and (v) coordinating monitoring and evaluating development programs that are financed by local and international partners6 This dual management consists of a central management unit at the PCM and Management central unit in MOSA The former is responsible for (i) co-managing the central NPTP database (ii) validating data and cross-checking with national databases (iii) processing household data and generating scores and ranks according to the proxy-means testing (PMT) formula (iv) maintaining the PMT formula (v) analyzing national data and reporting findings to the Social Inter-Ministerial Committee (Social-IMC) (vi) monitoring the NPTP targeting and (vii) auditing data processing The central unit in MOSA (through its SDCs)is responsible for (i) co-managing the central NPTP database (ii) receiving household applications (iii) interfacing with applicants (iv) entering data (v) conducting household visits (vi) checking for data errors (vii) transmitting data to the central database of the NPTP CMU and (viii) managing the public relations campaign

12

creation of the NPTP7 The present institutional setup will be retained during the implementation of the SPPP though the GOL has started discussing the possibility of consolidating the NPTP under MOSA and institutionalizing it as an independent program with its own budgetary allocations

This document is intended to look at designing the Environmental and Social Assessment Framework (ESAF) for the sub-projects to be financed under Component 2 of the SPPP

b Purpose of the Environmental and Social Assessment Framework (ESAF)

12 The ESAF is designed to ensure protection of the health and livelihood of beneficiaries and the environment The framework is intended to protect against both local impacts of individual sub-projects and the cumulative impact of many similar subprojects in the same area

13 Although many sub-projects have little or no adverse impact it is important nonetheless to acknowledge the possible unfavorable effects Experience shows that CDD projects need to establish simple social and environmental assessment procedures to avoid causing adverse harm to human health and the environment

14 The main elements of the Environmental and Social Assessment Framework (ESAF)are described below

Tools These tools usually include guidance written in the local language and presented in a form easily understood by community facilitators as well as

(i) rules-based social and environmental criteria establishing basic dorsquos and donrsquots and indicating the permissions and clearances required for common activities and(ii) mitigation guidelines providing practical guidance for the avoidance or mitigation of potential environmental impacts and identifying issues for which more specific expert guidance should be sought

Implementation Arrangements A description of roles and responsibilities to ensure that the identification avoidance and mitigation of environmental and social risks should be built into sub-project preparation appraisal and supervision This normally includes roles at the levels of community facilitators local management and program-wide management These should also be reflected in any Operational Manual that is prepared This description should abide by the rules and regulations issued by the Ministry of Environment

Capacity Building Training must be provided to ensure that every person with a role in the safeguard implementation arrangements is able to fulfill their responsibilities It is important that training in environmental and social safeguards management is incorporated from the very start of the program before the preparation of sub-projects begins

Supervision and Monitoring Arrangements should be in place to supervise both the adequacy and application of the safeguard management tools In addition it is useful to keep track of environmental concerns in program areas so that more specific mitigation measures can be

7Other options were considered at the time and are detailed in the EPP of the ESPISP II

13

designed and opportunities for enhancements can be promoted Secondary information gathering is usually sufficient for this purpose

Audit During preparation of the program it is useful to agree that an independent audit of the ESAF will be undertaken at mid-term to draw lessons and recommend improvements

15 Experience has shown the value of involving environmental organizations particularly those with advocacy expertise in the design of the Environmental and Social Assessment Frameworks and subsequently in the associated capacity building supervision and monitoring This in fact was done through the consultation process as it will be documented in later sections of this document Access to environmental expertise can be facilitated during program implementation through the identification of local professionals with an environmental background who can form a resource pool to be mobilized locally as subprojects require

16 Social funds and CDD programs also provide important opportunities to promote pro-poor reforms in environmental policies particularly those associated with access to natural resources and their management The involvement of national and local environmental specialists can play a valuable role in advancing these agendas

17 A development project mitigation measures (Annex I) encompass all actions taken to eliminate offset or reduce potentially adverse environmental impacts to acceptable levels Such measures are typically associated with the latter stages of project planning although in practice they may occur at any stage throughout the project cycle Normally potential impacts are identified early during the initiation and scoping stages of EA for a project and measures to avoid or minimize impacts are incorporated into the alternatives being considered In this respect some of the most important measures to protect the environment or local communities become integral to the project design and are never reflected within a formal environmental and social management plan (ESMP) For example the environmental and social bases for choosing a preferred location for a project will not necessarily be evident within the ESMP

18 Environmental and Social Management Plans (ESMPs) outline the mitigation monitoring and institutional measures to be taken during sub-project implementation and operation to avoid or control adverse environmental impacts and the actions needed to implement these measures They provide a crucial link between alternative mitigation measures evaluated and described within the EA report and ensuring that such measures are implemented EA reports are essentially planning documents with no legal basis In many cases mitigation measures outlined in EAs are described in illustrative terms or have neither been committed to by the borrower nor reflected in the project design In this regard the ESMP is a basis for negotiation and reaching agreement with borrowers on a sub-projectrsquos key social and environmental performance standards

19 This report aims at providing guidance in identifying environmental assessment needs for the various sub-projects that are funded under Component 2 of the SPPP and might have the potential of inflicting environmental impacts that need to be addressedFunded sub-projects fall under two categories

14

(i) Social Development (a) improving access to specialized social services to satisfy the needs of vulnerable groups at risk including the disabled children youth women and the elderly (b) enhancing environmental protection initiatives such as reforestation and soil erosion control wells and spring protection and preservation of natural sites

(ii) Income Enhancement Capacity building activities to support (a) micro and small entrepreneurs and non-governmental organizations providing credit to target beneficiary groups and (b) women youth and disabled people in order to provide them with demand driven specialized skills to improve their income and enhance their business opportunities

2 POLICY LEGAL amp INSTITUTIONAL FRAMEWORK FOR THE ENVIRONMENT

21 Regulatory Framework for Environmental Impact Assessment

20 Presently the environmental framework of Lebanon is managed and supervised by the Ministry of Environment (MOE) that was created by law 216 of April 2nd 1993 to be the government institution responsible for the development of a national strategy for sustainable development This was strengthened through the Law 4442002 Framework Law for the Protection of the Environment and the CEA (Country Environmental Analysis) The MOE is undergoing several review procedures to up-date the countryrsquos environmental policies and regulations including the preparation of an Environmental Code issuance of an Environmental Impact Assessment (EIA) decree as well as norms and standards for environmental protection The Environmental codes as well as the EIA decree were prepared with the assistance of the World Bank under the Mediterranean Environmental Technical Assistance Program (METAP) Also the World Bank has financed through METAP an assessment of the EIA System in Lebanon (Annex II)

METAP has also supported the establishment of an Environmental Management System Unit (EMSU) dealing with EIA at the MOE The concept of EA as part of project planning in Lebanon is still new and has only recently gained some attention The Environmental Impact Assessment (EIA) decree that was prepared by the MOE will require that an EIA be prepared during the planning process of both public and private development projects in Lebanon

22 Existing Environmental Legislation

221 International Conventions

21 The Lebanese Government has ratified a large number of international conventions for Environmental Protection Among the most important ones are

The Barcelona Convention for the protection of the Mediterranean SEA International Convention on World Heritage Protection International Convention on Bio-diversity Protection United Nations Convention on Desertification Montreal Protocol for the protection of the Ozone layer

15

222 Existing Lebanese Legislations

22 A list of the most significant existing environmental legislation is given in Annex II The primary safeguards as they are likely to affect SPPP subprojects are summarized in the following sections

Natural LandscapeProtection of the natural landscape of Lebanon was first addressed under the Law of January 1949 Recently cutting of trees was severely restricted under Decree No142 of March 1993 and further protection was provided under Law No 550 dated July 1996 There are also a number of Laws and Decisions that were issued to protect sites of particularly valuable landscape by declaring them Natural Reserves

Soil Water and Air PollutionProtection against pollution was first addressed by Decree No 8735 of October 1974 that prohibited the digging of wells for the disposal of raw sewage banned infiltration from cesspools and the use of sewage for the irrigation of vegetables and some fruits Decision No 521 of July 1996 introduced measures to deal with the pollution of the air water and soil including national standards for drinking water bathing waters and wastewater quality Recently Decision No 81 dated March 2001completed and reviewed the previously issued standards

Water ResourcesGround and surface water resources have been protected since the introduction of Order No 144 dated June 1925 which covered the major springs that supply the countryrsquos potable and irrigation needs Zoning of water sources and recharging of catchment areas was introduced by Decree 10276 of October 1962 to cope with increasing demand for water In 1970 Decree 14438 established a limit on the depth and exploitation of unlicensed wells and boreholes 150 m and 100 m3d respectively

Archaeological and Historical SitesThe protection of archaeological and historic sites was first addressed in Law No 1666 of November 1933 Later legislation has been introduced to afford special protection to the Cultural Heritage World Heritage and Cultural Landscape Sites declared by UNESCO

Public StreetsLaw No 60 of September 1983 covers Work in public streets law No 98 of September 1989 and by Circular 695 issued by the Prime Ministerrsquos Office on March 1995

Decree 86332012 on EIA describes clearly the various measures that need to be considered in the preliminary Environmental Evaluation of any project Projects found to require further investigation will have to be subjected to an EIA whereby complete set of information is required to allow for the Ministry to suggest needed mitigation measures and issue accordingly needed permits The stipulations of the decree go in hand with most of the WB guidelines The decree describes the various categories of sub-projects that do

16

require EIA and what are the projects that might cause risks and hazards A copy of the decree will be attached as an Annex to this document

23 Permit Procedures

23 Depending on the type and size of the sub-project to be executed and according to the Lebanese legislation a number of approvals and permits might be required from various governmental agencies In view of their nature and scale the majority of the sub-projects that would be funded by the SPPP will only require the approval of the municipality and or the Ministry of Municipalities and Rural Affairs

3 POTENTIAL SIGNIFICANT ENVIRONMENTAL IMPACTS AND GOOD PRACTICE MITIGATION PROCEDURES

31 Positive Environnemental Impact

24 Most sub-projects financed by the SPPP that are well designed and properly implemented can have a positive impact on the environment The benefits of this type of sub-projects are often long term rather than short term and are not limited to the specific local community Examples of environmentally beneficial sub-projects that will be financed by the SPPP are subject to case by case assessment soil erosion protection protection of natural and cultural heritage sites

a Consultation and Public Disclosure

25 A simple approach is proposed for public consultation in the early stages of sub-project preparation and planning

The stakeholders should be made aware of the different elements and features of each sub-project and their main objectives and target groups Once an ESIA has been made the results of this study should be disclosed to all concerned primary stakeholders

The stakeholders should then be encouraged to share their concerns worries and any comments they have on the sub-project or its likely impacts This should include discussions on alternative and proposed mitigation measures that are to be accounted for in the sub-project design implementation and operation phases

The final step is to incorporate the stakeholder inputs into the sub-project plans in order to improve the sub-project design

26 The process of stakeholder involvement and consultation will continue during sub-project implementation as well in order to integrate any additional comments and worries that may arise from the construction and implementation phase

27 Consultation with the stakeholders may take different forms depending on the need and subject matter that is being communicated An informative method would be through the use of one-way communication techniques such as audio (radio) visual (television) printed (leaflets brochures pictures diagrams posters) or electronic media (internet and electronic mail) In this case the stakeholders will be merely informed with certain information and there shall be no opportunity for questions or comments In order to have interactive consultation with the

17

stakeholders two-way participatory techniques are required This may include one-to-one briefings small group and village meetings and the organization of workshops and forums

28 The technique used for the disclosure and dissemination of information and data should take into consideration stakeholder preferences and characteristics The disclosed information should be in a language that all stakeholders are familiar with and for those who are illiterate certain measures may need to be taken to ensure that they are fully aware of the contents of the disclosed documents Another important consideration is that ample time should be given to the stakeholders to review the disclosed information prior to the consultation process to allow them to thoroughly address the sub-projects various issues

29 The SPPP will also generate environmental benefits through a variety of other mechanisms among which are

(a)- Generation of environmental assessment guidelines that can be used by other organizations or ministries or could be adopted by the Ministry of Environment for more general use

(b)- Training of environmental specialists thus increasing the number of environmental professionals in the country

(c)- Improved environmental awareness in the local communities

b Future capacity building initiatives

30 These could be done through a structured training along two parallel lines (i) at the level of the implementing agencies when these are guided one by one through the process by the environmental specialist to help them look at the needed assessment and the mitigation measures if any (ii) at the level of the community by organizing awareness campaigns targeted to LCP and other prominent figures and other interested CSOs on environmental issues of relevance and how that affects the sub-projects implemented in their areas That creates a social accountability system that could be used to ensure that the sub-projects are implemented according to appropriate procedures

32 Negative Environmental Impacts

321 Overview of Negative Environmental Impacts

31 The SPPP will finance a considerable number of different types of subprojects An important percentage of the funding will be allocated for social development Though intended to improve environmental and social conditions these subprojects can have a variety of negative environmental impacts that might be encountered during the operation of the subprojects Environmental impacts arising from the operation of the different subprojects can be minimized by appropriate site selection good engineering design and appropriate construction techniques

4 IMPLEMENTATION ARRANGEMENTS

41 Environmental Guidelines

18

32 The implementation of the SPPP falls under the responsibility of MOSA who would be in charge of coordinating the various activities through its Social Development Centers (SDCs) with concerned local governments and NGOs A Project Coordination Team (PCT) will be established and would comprise experts with relevant experience in implementing similar projects and with proven capacity to handle all functions required in such a project Among its mandates the PCT will ensure that any sponsored subproject is environmentally sound and sustainable

33 The PCT shall ensure the following

Environmental considerations will be included as criteria for selecting activities to be supported by the project environmental assessment would become an integral part of the project cycle of any subproject

Environmental guidelines are followed and used throughout the project cycle

Environmental issues are introduced to beneficiaries through education and promotion of environmentally beneficial subprojects

34 The execution of the CSD will be undertaken by Civil Society Organizations (CSO) who would consist of qualified local authorities or national NGOs with strong community ties and proven execution capacity The SDC would assist local NGOs LCF and communities in identifying local needs preparing subprojects coordinating with concerned ministries and implementing the subprojects

42 Environmental Assessment (EA)

35 The World Bank Operational Policy (OP 401) on Environmental Assessment (January 1999) defines the Bankrsquos environmental assessment requirements to ensure that funded sub-projects are environmentally sound and sustainable A screening process is undertaken for all funded sub-projects to assess the magnitude and adversity of predicted environmental impacts and to determine the appropriate extent and type of EA Depending on the type location sensitivity and scale of the project as well as the nature and magnitude of environmental impacts sub-projects are classified into one of three categories

(a)- Category A Sub-Projects that are likely to cause significant and possibly irremediable environmental impacts

(b)- Category B Sub-Projects that might cause lesser adverse impacts than those of Category A and the impacts are often remediable or could be mitigated for

(c)- Category C Sub-Projects which could have minimal or no adverse environmental impacts

19

36 The SPPP will only fund sub-projects that can be classified as either Category B or Category C only For instance all income enhancement sub-projects will be classified as Category C while most social sub-projects will be Category B Sub-projects that are likely to cause substantial negative impacts and are expected to fall in Category A will not be approved for funding

37 This document will provide guidance with respect to the preparation of environmental assessment for the various funded subprojects These guidelines are based on the World Bank Operational Policies (OP 401) the Environmental Assessment Source book (1991) and its updates in addition to the Decree 86332012 on EA issued by the GOL

5 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

51 Objectives and Structure of the ESMP

38 The objectives of the ESMP are to mitigate the adverse environmental impacts identified in the SPPP The ESMP will consist of three kinds of activities

o Implementation of mitigation measures o Strengthening the capacities of PCT SDCs and local NGOs o Monitoring and evaluation of mitigation measures identified during subproject

formulation or within the environmental assessment report

52 Implementation of Mitigation Measures

39 Mitigation measures identified (Table 1) are for typical sub-projects and MOSAPCT will ensure that such measures are adhered to during the overall implementation of the SPPP

Table 1 Potential Environmental Impacts and Proposed Mitigation Measures for Different Subprojects

Project Component

Potential Impacts Mitigation Measures Responsibility

Roads rehabilitation

Clogging of natural drainage channelsEncroachment on private property

Dumping of construction wastes and accidental spills of machine fuels etcRisk of damage to unknown archaeological sites

Maintain ditches

Detailed property boundary surveys and flagging in fieldProper disposal of construction wastes

Use ldquochance findrdquo procedures and coordinate with appropriate

Contractor

ContractorIA

Contractor

IAsArcheology department

20

government agency

Rehabilitation of schools

Rehabilitation of health clinics

Irrigation and drainage

Improper disposal of wastes

Water quality degradation in ponds and reservoirsClogging of canals from weedssedimentsInefficient water flow because of heavy sedimentation

Degradation of water systems receiving irrigation waters by nutrients agrochemical and salts

Proper disposal of solid wastesPriority given to rehabilitation of toiletsInstallation of sanitation (cesspools)

Containerize infectious wastesPublic health awareness

Monitoring of water qualityOperation amp maintenance planProper design of canals and provision of access for weed and sediments removal

Control of agrochemical use

IAsMunicipality

IAscommunity

IAscommunity

Ministry of Health

Ministry of Energy and Water

IAs community

ContractorIAs

Ministry of Agriculturecommunity

53 Training Program and Capacity Building

40 The MOSA lacks the capacities and the expertise to work in the field of environmental monitoring and protection Moreover it is expected that the IAs mostly CSOs and SDCs do not have the needed resources to undertake the requirements needed in terms of EAs and designing mitigation measures This would require a detailed capacity building program that targets all levels of the decision making process in the project The central team at the MOSA and the PCT need to be oriented to the general approach to environmental safeguards importance use and how that could affect the selection implementation and monitoring of Sub-projects SDFCs and IAs should be trained on

21

the technical aspects of detection and mitigation and how these could be imbedded within the process of project identification to formulation to implementation These safeguards will have to be an integral part of any sub-project proposal and consequently any detailed action plan for any specific sub-project Environmental expertise within the implementing and executing bodies will be strengthened Training programs will designed and implemented with the assistance of a local or international expert and will target levels as stated in the Table 2 page 20

41 PCT and IAs At the initiation of the CSD and prior to bidding and selection of IAs a workshop will be provided and will include an environmental session to raise environmental awareness and to clarify the specific environmental requirements related to design and implementation of the SPPP

42 Another training workshop will be provided to the PCT and selected IAs and will cover the following to IAs

EIA techniques Screening sub-projects for environmental review Use of practical formschecklists Best environmental practices in design and implementation of projects Effective implementation of mitigation measures Project supervision Monitoring and evaluation

43 Local NGOs and Contractors IAs will be required to provide workshops for local NGOs and contractors focusing on public awareness case studies of environmental issues experienced in similar projects use of environmental guidelines and implementation of mitigation measures (Table 2 Annex III)

22

Table 2 Training and Capacity Building Program for Implementing the ESAFTraining

Capacity BuildingParticipating Stakeholders

Skills acquired Scheduling Cost Source

ManagementInstitutional

1year

SPPP manager MOSA central unit Head of concerned

departments at MOSA PCT

Decision making and delegation Work procedures Environmental awareness National guidelines WB guidelines Classification and mitigation

Prior to sub-project preparation Planning phase Refresher every 3 months as we

go along the project

Undertaken by the Environmental

SpecialistMiscellaneous

7500 USD

WBMOSA

Institutional at Intermediate levels

2 training sessions of 2 days year

(for SDC and IA X5 regions)

PCT Emanating committee SDC managers IAs

Environmental and social policies

Laws and regulations GOL and WB safeguards Evaluation and selection

During sub-project preparation Planning phase Sub-project evaluation

Undertaken by the Environmental

SpecialistMiscellaneous

30000 USD

WB MOSA

Implementation1 day session X2 year X 5 regions

IAs SDC staff Beneficiaries Municipalities

Environment and social tools Screening amp monitoring

methods Sustainability of the process Practical mitigation and

safeguards

During sub-project preparation Mobilization Implementation

Undertaken by the Environmental

SpecialistMiscellaneous

50000 USD

WB MOSA

Monitoring Evaluation and

Reporting1 dayX2 year X5

regions

IAs SDC staff Beneficiaries

Municipalities

Environmental and social monitoring and compliance

Progress report preparation Monitoring and Evaluation

During sub-project preparation MobilizationImplementation

Environmental Specialist + consultant

50000 USD

WB MOSA

Total 137500 USD (includes in kind contribution from MOSA)

23

54 Environmental Monitoring

44 Environmental Monitoring will be the responsibility of the ES PCT and MOSA Central Unit with the supervision of the LCP and will include compliance monitoring during implementation and also monitoring of significant impacts during the operation of the subproject

Table 3 Typical Examples of Monitoring Plan for the Operation of Different Subprojects

Sub-project Monitoring Indicators Responsibility FrequencyRoads rehabilitation

Operating drainage channels

NGOs in close coordination with local community

Semi-annual assessment

Improvements to Water Supply and Sanitation Facilities

Irrigation and drainage

Distribution network without leaksNo leakage or overflows of manholes or drainsWater Quality Monitoring

Irrigation network without leaksDrainage channels clean and properly maintainedWater quality parameters (pH COD BOD SS)

NGOs in close coordination with local community

Ministry of Health and Ministry of Energy and Water

NGOs in close coordination with local community

Testing by Ministry of Health and Ministry of Energy and Water

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Rehabilitation of schools

Rehabilitation of health clinics

Toilet facilities clean and functioning properlyDrinking water faucets clean and safe from contamination

NGOs in close coordination with local community and appropriate municipality

Ministry of Health in close coordination with local community

Semi-annual assessment

Semi-annual assessment

23

24

45 The Environmental Specialist (ES) of the PCT will also conduct periodic monitoring by visiting the sites of the various sub-projects at least twice during the implementation period of the sub-project

46 Monitoring indicators shall be developed for both the mobilization and the operation phase of the subprojects Monitoring of activities will have to ensure that mitigation measures of operations impacts are being implemented properly while the monitoring of operation is to ensure that no unforeseen negative impacts are arising

55 Sub-project Cycle

47 Component 2 of the SPPP is the Community Social Development Program (CSD) which will be financing community-based sub-projects through grants The Program will have two windows one for social services whereas the other is for Income Generation Activities (IGA) support with the review and approval mechanisms in large part being the same for both windows While Component 3 focuses on Poverty Targeting thus the services provided will have no impact on the environment component 1 will focus on the provision of technology and training to SDCs

48 Applicants will be invited to use standard forms (available on the MOSA website and upon request from SDCs) to submit proposals to the relevant SDC in cases where the applicant is the SDC itself the application will be submitted directly to the CSD program team in Beirut

49 SDCs will immediately check all proposals for completeness and give a receipt to the applicant with a proposal number proposals found to be incomplete will be rejected with an explanation All complete proposals will be presented for discussion to the relevant Local Community Platform (LCP) or equivalent consultative body to obtain feedback on among other things the actual need (in case of social services) or likely market value (in the case of IGA) of the proposed activity the reputation of the applicant the likely sustainability of the proposed activity the preliminary classification of the project within environmental categories (the final classification will be pending on the decision of the environmental specialist within the PCT) any problematic aspect (conflict of interest etc) and the overall compliance of the proposal with the purposes of the program This feedback is not binding but will be taken into consideration when deciding whether or not to fund the proposal The CSD program team will carry out a detailed desk review of all complete proposals to assess their technical quality as well as the budget and time line suggested for the sub-project The environmental specialist member of the Project Coordinating Team (PCT) will review the proposal and prepare all needed documentation based on his classification of the sub-project

56 Screening of Sub-Projects

50 Each sub-project to be implemented by an IA will be subjected to an environmental screening Using the screening form (Form 1) environmental and social checklists for the proposed sub-projects will be screened by the environmental specialist to identify any potential adverse impacts

25

From an environmental standpoint the screening form may identify impacts form sub-projects the issue of solid waste disposal at the site of a sub-project may come out as a point to look at in terms of designing mitigation measures to avoid negative impacts The selection of adequate storage collection and proper disposal could be steps to consider carefully

57 The Environmental and Social Screening Process

51 The objectives of sub-project screening is to determine which activities are likely to have negative environmental and social impacts

571 Subproject Screening Procedures

52 The sub-projects funded under this project are generally categorized as Category B or C and screening mechanisms would ensure that any identified Category A sub-projects are not funded under the project Due to the fact that most Category B sub-projects are small-scale which do not result in adverse negative environmental impacts this will require an ESMP which has clear due diligence environmental and social procedures (including the setting out of institutional responsibilities timing and budget) for sub-projects The ESMP should take into consideration the applicable requirements under the Bankrsquos ten safeguard policies

572 Environmental Sub-Project Screening Checklistsforms

53 The Operation Manual (OM) should contain for each type of sub-project a simple environmental screening checklist (Form 1)) which poses a series of questions designed to identify risks to the environment The goal of the checklist (also called a screening or environmental data sheet) is to identify which sub-projects require more environmental information in the form of a site-specific ESMP or which can proceed without any special mitigation measures that is falling under category C

Form 1 Environmental Screening Check-list

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

3

TABLE OF CONTENTSList of Acronyms and abbreviations

EXECUTIVE SUMMARY 5

1 INTRODUCTION11 Background 712 Implementation 11

a Institutional amp Implementation Arrangements 11b Purpose of the Environmental Social Assessment Framework (ESAF) 12

2 POLICY LEGAL ADMINISTRATIVE amp ENVIRONMENTAL FRAMEWORK

21 Regulatory Framework for Environmental Impact Assessment 1422 Existing Environmental Legislations 14

221 International Conventions 14222 Existing Lebanese Legislations 15

23 Permit procedures 16

3 POTENTIAL SIGNIFICANT ENVIRONMENTAL IMPACTS ampMITIGATION PROCEDURES

31 Positive Environmental Impact 16311 Consultation amp Public Disclosure 16312 Future Capacity Building Initiatives 17

32 Negative Environmental Impact amp Mitigation Measures 17

4 IMPLEMENTATION ARRANGEMENTS41 Environmental Guidelines 1842 Environmental Assessment 18

5 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)51 Objectives amp Structure of the ESMP 1952 Implementation of Mitigation Measures 1953 Training Program amp Capacity Building 2054 Environmental Monitoring 2355 Sub-project Cycle 2456 Screening of Sub-projects 2457 Environmental amp Social Screening Process 25

571 Sub-project Screening Procedures 25572 Environmental Sub-project Screening Checklist 25

4

573 Assign Environmental Categories 28574 Carrying Out Environmental Work 28575 Review and Approval 28576 Monitoring and Follow Up 29577 Monitoring Indicators 29

58 Staffing amp Capacities of MOSA in Environmental Safeguards 29

6 ENVIRONMENTAL REVIEW PROCEDURES amp GUIDELINES61 Status of the SPPP Environmental Review 3262 Institutional Arrangement 3263 Program Cycle 3364 Promotion of sub-projects 3465 Formulation of Sub-projects 3466 Appraisal amp Approval of Proposed Programs 3567 Implementation amp Monitoring 35

ANNEXES

ANNEX I PRIMARY OBJECTIVES OF MITIGATION MEASURES 36ANNEX II ENVIRONMENTAL FRAMEWORK IN LEBANON 37ANNEXIII TERMS OF REFERENCE FOR THE PREPARATION OF THE

ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)43

Table 1 ESMP TEMPLATES (MITIGATION MEASURES) 47Table 2 ESMP TEMPLATES (TRAINING amp CAPACITY BUILDING) 48Table 3 ESMP TEMPLATES (MONITORING) 49

ANNEX IV PUBLIC CONSULTATION 50

5

EXECUTIVE SUMMARY

This Report has been prepared to present the environmental requirements and guidelines for the Social Promotion and Protection Project (SPPP) that the Government of Lebanon is planning to initiate through the Ministry of Social Affairs (MOSA)

Project DescriptionThe project consists of three components (i) developing the role and capacity of Social Development Centers (SDCs) (ii) establishing and supporting an effective national program in MOSA to finance community developed and driven projects and (iii) continued roll-out and institutionalization of the National Poverty Targeting Program (NPTP)

This Environmental Social Assessment Framework (ESAF) is designed to ensure protection of the health and livelihood of beneficiaries and the environment The framework is intended to protect against both local impacts of individual subprojects and the cumulative impact of many similar subprojects in the same area

Many subprojects have little or no adverse impact However it is important to acknowledge possible unfavorable effects Experience shows that CDD projects need to establish simple social and environmental assessment procedures to avoid causing adverse harm to human health and the environment

The main elements of the Environmental Social Assessment Framework are (1) Tools These tools usually include guidance written in the local language and presented in a form easily understood by community facilitators (2)Implementation Arrangements A description of roles and responsibilities to ensure that the identification avoidance and mitigation of environmental and social risks should be built into sub-project preparation appraisal and supervision (3) Capacity Building Training must be provided to ensure that every person with a role in the safeguard implementation arrangements is able to fulfill their responsibilities (4) Supervision and Monitoring Arrangements should be in place to supervise both the adequacy and application of the safeguard management tools (5) Audit During preparation of the program it is useful to agree that an independent audit of the Safeguards Management Framework will be undertaken at mid-term to draw lessons and recommend improvements

The implementation of the SPPP falls under the responsibility of MOSA who would be in charge of coordinating the various activities through its Social Development Centers (SDC) with concerned local governments and NGOs A Project Coordination Team (PCT) will be established and would comprise experts with relevant experience in implementing similar projects and with proven capacity to handle all functions required in such a project Among its mandates the PCT will ensure that any sponsored subproject is environmentally sound and sustainableThe World Bank Operational Policy (OP 401) on Environmental Assessment (January 1999) defines the Bankrsquos environmental assessment requirements to ensure that funded projects are

6

environmentally sound and sustainable A screening process is undertaken for all funded projects to assess the magnitude and adversity of predicted environmental impacts and to determine the appropriate extent and type of EA Depending on the type location sensitivity and scale of the project as well as the nature and magnitude of environmental impacts projects are classified into one of three categories

(a)- Category A Projects that are likely to cause significant and possibly irremediable environmental impacts

(b)- Category B Projects that might cause lesser adverse impacts than those of Category A and the impacts are often remediable or mitigable

(c)- Category C Projects which could have minimal or no adverse environmental impacts

Subprojects funded by the SPPP are classified as Category B or Category C Sub-projects found to be category A as per World Bank environmental safeguards classification will not be funded by the project

Following this division sub-projects falling only under categories B will need Environmental and Social Management Plans (ESMPs) to be prepared and reviewed for clearance prior to providing final approval for the sub-project

This document describes the needed step and tools that need to be looked at in the design of the sub-project as well as the mitigation measures needed for implementation that takes into account all environmental and social considerations and thus mitigates for any negative impacts in this regard

7

1 INTRODUCTION

11 Background

This document constitutes an integral part of the Project Appraisal Document intended for a World Bank loan to the Government of Lebanon at a total value of USD 30 Million for the implementation of the Social Promotion and Protection Project (SPPP) It has been prepared to present the environmental requirements and guidelines for the SPPP that the Government of Lebanon is planning to initiate through the Ministry of Social Affairs (MOSA)

PROJECT DEVELOPMENT OBJECTIVES

A Project Development Objective

1 The development objective of SPPP is to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

Project Beneficiaries

2 The SPPP beneficiaries consist of the following three categories

(a) Poor and Vulnerable Households and Community Members The ultimate beneficiaries of the project include (a) vulnerable individuals and households (eg children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) who will have improved access to social services provided by SDCs (b) poor and vulnerable individuals who will receive assistance through income generating activities (IGAs) as well as others in the community who will find new employment or experience increased earnings stimulated by growth of IGAs and (c) the poor households who will be eligible to receive NPTP benefits

(b) MOSA The project will help strengthen MOSArsquos capacity to carry out its official mandate both at the central level and through the SDCs at the local levels In particular MOSA will be supported in managing the implementation of small projects using a community-based demand-driven and participatory approach so as to position itself as the main government actor for community development activities in the social sphere At the same time the continued implementation of the NPTP will help MOSA develop the skills needed for administering well-targeted and efficient social safety nets

(c) Civil Society Organizations (CSOs) CSOs will also benefit from the project as they will have an opportunity to improve their capacity to propose prepare and implement income-generating projects and social services at the community level

8

B Project Components

3 The SPPP will have the following four components (1) Social Development Centers (SDCs) (2) Community Social Development Program (CSD) (3) National Poverty Targeting Program (NPTP) and (4) Project Coordination Team (PCT) Component 1 which focuses on building the capacity of the SDCs is cross-cutting between Components 2 and 3 as the SDCs are the local implementing arms of MOSArsquos mandate Specifically both the CSD and NPTP programs rely on the SDCs for implementation

Component 1 Social Development Centers (SDCs) (US$952 million total cost of which US$908 million to be financed from the loan)

4 The objective of this component is to enhance the administrative and operational capacity of the SDCs to enable them to offer social services of improved quality and relevance This component will also include key cross-component functions such as monitoring and evaluation social accountability measures and communication outreach To achieve the above this component will consist of the following sub-components

(a) Equipping automating and electronically linking the SDCs to the central unit at MOSA The project will finance (i) necessary equipment and software to computerize systems and processes at the SDCs (eg creating databases) and to ensure proper processing of NPTP transactions (ii) the establishment of a computerized modular MIS with dedicated modules for the CSD and NPTP1 programs as well as for other core functions (eg procurement financial management) and accessible to both SDCs and the central MOSA unit (iii) internet connectivity between the SDCs and MOSA and (iv) small works and equipment to refurbish and rehabilitate the SDCs as needed

(b) Building and empowering the human resources of the SDCs The project will finance training of SDC staff including in (i) the use of new equipment and systems (ii) specific topics to support the implementation of the CSD and NPTP programs such as handling grievances writing proposals and applying case management and participatory approaches

(c) Community participation The project will finance capacity building and technical assistance for SDCs to (i) establish mechanisms at the SDC level to facilitate community consultation in the SDC catchment area in the form of ldquoLocal Consultative Platformsrdquo (LCP) and (ii) create inventories of local social service providers carry out social needs assessments and prioritization and establish referral systems to ensure that social services match community needs

(d) Monitoring and Evaluation Social Audits and Communication Outreach (see Section IV B for further details) The project will finance the development of a comprehensive MampE system relying primarily on the computerized MIS as well as training of MOSA staff and the project team to use it This will include assessing the performance of the present NPTP MampE system improving it as needed and

1 As an NPTP module is already in use any needed upgrading will be handled under the NPTP Component

9

carrying out short surveys on a regular basis (eg opinion polls) As part of the monitoring effort as well as to promote good governance this component will finance social audits Communication outreach campaigns for the NPTP and the CSD programs will also be supported

Component 2 Community Social Development Program (CSD) (US$1729 million total cost of which US$1232 million to be financed from the loan)

5 This component aims to establish a transparent accountable and efficient national CSD program that will finance community-based sub-projects through grants The CSD program is designed building on the experience of the World Bank-supported Community Development Project (2001-2008) MOSA experiences as well as lessons learnt from other CDD programs in Lebanon and around the world Grant sizes are limited to US$50000 equivalent implementation time for each sub-grant is one year and beneficiaries will be required to make contributions upfront Targeting will be done according to two criteria (a) geographic targeting to prioritize areas of greater poverty and deprivation (eg Akkar district) based on information from updated poverty estimates and studies carried out by various donors (eg the European Union) and (b) categorical targeting to prioritize vulnerable groups (eg the handicapped) based on MOSArsquos mandate The component will consist of the following two sub-components

(a) Establishment of a National Community Social Development Program in MOSA the project will finance technical assistance in the form of key experts (eg CSD program manager engineer social specialist income-generating specialist) who will manage a transparent process of calls for proposals screening and prioritization of proposals and monitoring and supervision of sub-grant implementation

(b) Funding community-driven sub-projects The project will provide grants to eligible applicants (primarily SDCs and CSO) whose projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

10

Component 3 National Poverty Targeting Program (NPTP) (US$17286 million total cost of which US$665 million to be financed from the loan)

6 This component aims to expand the coverage from approximately 100300 (expected in 2013 baseline of SPPP) to 238700 (in 2018) individual beneficiaries as well as to improve the efficiency of the NPTP To achieve this objective the project will provide technical support for the continued roll-out and institutionalization of the NPTP which was launched in 2011 under the Bank-financed Second Emergency Social Protection Implementation Support Project (ESPISP II) Presently NPTP benefits consist of waived school and hospitalization fees coverage of chronic disease medications free schoolbooks and discounts on electricity bills The cost of these benefits as well as that of the SDC social workers involved in administering the program are being borne and will continue to be borne by the Government2 To achieve its objective this component will consist of the following three sub-components

(a) Continued roll-out and institutionalization The project will finance technical assistance for (i) supporting the program management team (ii) refining the program application forms and Proxy-Mean Testing (PMT) questionnaire (iii) upgrading the MIS module for the NPTP and establishing an archiving system (iv) adopting measures to prevent and discourage fraud and corruption (v) refining the grievance and redress mechanism for improved efficiency and transparency

(b) Access to social safety nets The project will finance technical assistance for (i) assessing the performance of the reimbursement mechanism of the NPTP benefits and designing any improvements and (ii) designing and piloting a case management approach with NPTP beneficiary households

(c) Enabling evidence-based policy making for poverty reduction The project will finance (i) technical assistance to support the Inter-ministerial Committee for Social Policy (Social-IMC) and its Secretariat (ii) technical assistance to establish a Poverty Analysis Team whose role will be to assess the poverty and inequality situation in Lebanon using Household Budget Survey (HBS) data and (iii) the design and implementation of the next HBS (in 2017) which will be a large-sample survey representative at the governorate (mohafazat) level

Component 4 Project Coordination Team (PCT) (US$214 million out of which US$195 from the loan)

7 The project will finance a team who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components (see Section III and Annex IV of the Project Appraisal Document) reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively

2 The Council of Ministers allocated US$28 million in 2011 to finance the benefits and approximately US$4 million for the hiring of 350 social workers

11

contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management

12 IMPLEMENTATION

a Institutional and Implementation Arrangements

8 MOSA is the project implementing agency and it will oversee the implementation of all SPPP activities A Project Coordinator will head the PCT and also be responsible for the implementation of Component 1 assisted by a Project Officer while Components 2 and 3 will each be headed by a Program Manager These positions will be financed by project funds A combination of contracted and MOSA staff will be responsible for the implementation of component activities

9 Each component will be overseen by a MOSA committee that will report to the Minister In the case of Components 2 and 3 the committee will be an ldquoEmanating Project Committeerdquo3 which will check the legal aspect of all activities financed and implemented by the component (which is considered an ldquoemanating projectrdquo) and oversee the way the funds are being spent In the case of Component 1 the committee will be a SDC Committee consisting of the SDC Director and other MOSA staff4

10 The heads of the components and the MOSA Minister (as well as the Director General if the position is filled) will form the SPPP Steering Committee which will meet periodically to review implementation progress and ensure coherence with ministry policies At the national policy level the Social Inter-Ministerial Committee (Social-IMC) with MOSA acting as its Technical Secretariat will ensure coordination of the SPPP with other social policies5 Further details are provided in Annex 3 of the Loan Agreement

11 With respect to the institutional setup of the NPTP the program has been operating under a ldquodual managementrdquo by MOSA and the Presidency of the Council of Ministers (PCM)6 This was deemed the best option at the time of appraisal of the ESPISP II project which supported the

3Emanating Project Committees are established as a way to circumvent the cumbersome Lebanese bureaucracy while still providing appropriate oversight They generally comprise five or six members taken from high-ranking positions within the Ministry (eg Department Directors)4 Each SDC has its own Emanating Committee so it would not be possible to also have an Emanating Committee overseeing the component5The Social-IMC established on January 22 2007 by a decree signed by the Prime Minister and composed of the Ministers of Finance Social Affairs Health Education Labor Interior amp Municipal Affairs Economy amp Trade NSSF and the President of CDR is charged with (i) drafting a comprehensive integrated and coordinated social strategy (ii) coordinating government activities for the provisions of social services (iii) ensuring coordination of all studies surveys reports related to social affairs and ensuring availability of relevant social data and indicators (iv) overseeing the implementation of social safety net programs and (v) coordinating monitoring and evaluating development programs that are financed by local and international partners6 This dual management consists of a central management unit at the PCM and Management central unit in MOSA The former is responsible for (i) co-managing the central NPTP database (ii) validating data and cross-checking with national databases (iii) processing household data and generating scores and ranks according to the proxy-means testing (PMT) formula (iv) maintaining the PMT formula (v) analyzing national data and reporting findings to the Social Inter-Ministerial Committee (Social-IMC) (vi) monitoring the NPTP targeting and (vii) auditing data processing The central unit in MOSA (through its SDCs)is responsible for (i) co-managing the central NPTP database (ii) receiving household applications (iii) interfacing with applicants (iv) entering data (v) conducting household visits (vi) checking for data errors (vii) transmitting data to the central database of the NPTP CMU and (viii) managing the public relations campaign

12

creation of the NPTP7 The present institutional setup will be retained during the implementation of the SPPP though the GOL has started discussing the possibility of consolidating the NPTP under MOSA and institutionalizing it as an independent program with its own budgetary allocations

This document is intended to look at designing the Environmental and Social Assessment Framework (ESAF) for the sub-projects to be financed under Component 2 of the SPPP

b Purpose of the Environmental and Social Assessment Framework (ESAF)

12 The ESAF is designed to ensure protection of the health and livelihood of beneficiaries and the environment The framework is intended to protect against both local impacts of individual sub-projects and the cumulative impact of many similar subprojects in the same area

13 Although many sub-projects have little or no adverse impact it is important nonetheless to acknowledge the possible unfavorable effects Experience shows that CDD projects need to establish simple social and environmental assessment procedures to avoid causing adverse harm to human health and the environment

14 The main elements of the Environmental and Social Assessment Framework (ESAF)are described below

Tools These tools usually include guidance written in the local language and presented in a form easily understood by community facilitators as well as

(i) rules-based social and environmental criteria establishing basic dorsquos and donrsquots and indicating the permissions and clearances required for common activities and(ii) mitigation guidelines providing practical guidance for the avoidance or mitigation of potential environmental impacts and identifying issues for which more specific expert guidance should be sought

Implementation Arrangements A description of roles and responsibilities to ensure that the identification avoidance and mitigation of environmental and social risks should be built into sub-project preparation appraisal and supervision This normally includes roles at the levels of community facilitators local management and program-wide management These should also be reflected in any Operational Manual that is prepared This description should abide by the rules and regulations issued by the Ministry of Environment

Capacity Building Training must be provided to ensure that every person with a role in the safeguard implementation arrangements is able to fulfill their responsibilities It is important that training in environmental and social safeguards management is incorporated from the very start of the program before the preparation of sub-projects begins

Supervision and Monitoring Arrangements should be in place to supervise both the adequacy and application of the safeguard management tools In addition it is useful to keep track of environmental concerns in program areas so that more specific mitigation measures can be

7Other options were considered at the time and are detailed in the EPP of the ESPISP II

13

designed and opportunities for enhancements can be promoted Secondary information gathering is usually sufficient for this purpose

Audit During preparation of the program it is useful to agree that an independent audit of the ESAF will be undertaken at mid-term to draw lessons and recommend improvements

15 Experience has shown the value of involving environmental organizations particularly those with advocacy expertise in the design of the Environmental and Social Assessment Frameworks and subsequently in the associated capacity building supervision and monitoring This in fact was done through the consultation process as it will be documented in later sections of this document Access to environmental expertise can be facilitated during program implementation through the identification of local professionals with an environmental background who can form a resource pool to be mobilized locally as subprojects require

16 Social funds and CDD programs also provide important opportunities to promote pro-poor reforms in environmental policies particularly those associated with access to natural resources and their management The involvement of national and local environmental specialists can play a valuable role in advancing these agendas

17 A development project mitigation measures (Annex I) encompass all actions taken to eliminate offset or reduce potentially adverse environmental impacts to acceptable levels Such measures are typically associated with the latter stages of project planning although in practice they may occur at any stage throughout the project cycle Normally potential impacts are identified early during the initiation and scoping stages of EA for a project and measures to avoid or minimize impacts are incorporated into the alternatives being considered In this respect some of the most important measures to protect the environment or local communities become integral to the project design and are never reflected within a formal environmental and social management plan (ESMP) For example the environmental and social bases for choosing a preferred location for a project will not necessarily be evident within the ESMP

18 Environmental and Social Management Plans (ESMPs) outline the mitigation monitoring and institutional measures to be taken during sub-project implementation and operation to avoid or control adverse environmental impacts and the actions needed to implement these measures They provide a crucial link between alternative mitigation measures evaluated and described within the EA report and ensuring that such measures are implemented EA reports are essentially planning documents with no legal basis In many cases mitigation measures outlined in EAs are described in illustrative terms or have neither been committed to by the borrower nor reflected in the project design In this regard the ESMP is a basis for negotiation and reaching agreement with borrowers on a sub-projectrsquos key social and environmental performance standards

19 This report aims at providing guidance in identifying environmental assessment needs for the various sub-projects that are funded under Component 2 of the SPPP and might have the potential of inflicting environmental impacts that need to be addressedFunded sub-projects fall under two categories

14

(i) Social Development (a) improving access to specialized social services to satisfy the needs of vulnerable groups at risk including the disabled children youth women and the elderly (b) enhancing environmental protection initiatives such as reforestation and soil erosion control wells and spring protection and preservation of natural sites

(ii) Income Enhancement Capacity building activities to support (a) micro and small entrepreneurs and non-governmental organizations providing credit to target beneficiary groups and (b) women youth and disabled people in order to provide them with demand driven specialized skills to improve their income and enhance their business opportunities

2 POLICY LEGAL amp INSTITUTIONAL FRAMEWORK FOR THE ENVIRONMENT

21 Regulatory Framework for Environmental Impact Assessment

20 Presently the environmental framework of Lebanon is managed and supervised by the Ministry of Environment (MOE) that was created by law 216 of April 2nd 1993 to be the government institution responsible for the development of a national strategy for sustainable development This was strengthened through the Law 4442002 Framework Law for the Protection of the Environment and the CEA (Country Environmental Analysis) The MOE is undergoing several review procedures to up-date the countryrsquos environmental policies and regulations including the preparation of an Environmental Code issuance of an Environmental Impact Assessment (EIA) decree as well as norms and standards for environmental protection The Environmental codes as well as the EIA decree were prepared with the assistance of the World Bank under the Mediterranean Environmental Technical Assistance Program (METAP) Also the World Bank has financed through METAP an assessment of the EIA System in Lebanon (Annex II)

METAP has also supported the establishment of an Environmental Management System Unit (EMSU) dealing with EIA at the MOE The concept of EA as part of project planning in Lebanon is still new and has only recently gained some attention The Environmental Impact Assessment (EIA) decree that was prepared by the MOE will require that an EIA be prepared during the planning process of both public and private development projects in Lebanon

22 Existing Environmental Legislation

221 International Conventions

21 The Lebanese Government has ratified a large number of international conventions for Environmental Protection Among the most important ones are

The Barcelona Convention for the protection of the Mediterranean SEA International Convention on World Heritage Protection International Convention on Bio-diversity Protection United Nations Convention on Desertification Montreal Protocol for the protection of the Ozone layer

15

222 Existing Lebanese Legislations

22 A list of the most significant existing environmental legislation is given in Annex II The primary safeguards as they are likely to affect SPPP subprojects are summarized in the following sections

Natural LandscapeProtection of the natural landscape of Lebanon was first addressed under the Law of January 1949 Recently cutting of trees was severely restricted under Decree No142 of March 1993 and further protection was provided under Law No 550 dated July 1996 There are also a number of Laws and Decisions that were issued to protect sites of particularly valuable landscape by declaring them Natural Reserves

Soil Water and Air PollutionProtection against pollution was first addressed by Decree No 8735 of October 1974 that prohibited the digging of wells for the disposal of raw sewage banned infiltration from cesspools and the use of sewage for the irrigation of vegetables and some fruits Decision No 521 of July 1996 introduced measures to deal with the pollution of the air water and soil including national standards for drinking water bathing waters and wastewater quality Recently Decision No 81 dated March 2001completed and reviewed the previously issued standards

Water ResourcesGround and surface water resources have been protected since the introduction of Order No 144 dated June 1925 which covered the major springs that supply the countryrsquos potable and irrigation needs Zoning of water sources and recharging of catchment areas was introduced by Decree 10276 of October 1962 to cope with increasing demand for water In 1970 Decree 14438 established a limit on the depth and exploitation of unlicensed wells and boreholes 150 m and 100 m3d respectively

Archaeological and Historical SitesThe protection of archaeological and historic sites was first addressed in Law No 1666 of November 1933 Later legislation has been introduced to afford special protection to the Cultural Heritage World Heritage and Cultural Landscape Sites declared by UNESCO

Public StreetsLaw No 60 of September 1983 covers Work in public streets law No 98 of September 1989 and by Circular 695 issued by the Prime Ministerrsquos Office on March 1995

Decree 86332012 on EIA describes clearly the various measures that need to be considered in the preliminary Environmental Evaluation of any project Projects found to require further investigation will have to be subjected to an EIA whereby complete set of information is required to allow for the Ministry to suggest needed mitigation measures and issue accordingly needed permits The stipulations of the decree go in hand with most of the WB guidelines The decree describes the various categories of sub-projects that do

16

require EIA and what are the projects that might cause risks and hazards A copy of the decree will be attached as an Annex to this document

23 Permit Procedures

23 Depending on the type and size of the sub-project to be executed and according to the Lebanese legislation a number of approvals and permits might be required from various governmental agencies In view of their nature and scale the majority of the sub-projects that would be funded by the SPPP will only require the approval of the municipality and or the Ministry of Municipalities and Rural Affairs

3 POTENTIAL SIGNIFICANT ENVIRONMENTAL IMPACTS AND GOOD PRACTICE MITIGATION PROCEDURES

31 Positive Environnemental Impact

24 Most sub-projects financed by the SPPP that are well designed and properly implemented can have a positive impact on the environment The benefits of this type of sub-projects are often long term rather than short term and are not limited to the specific local community Examples of environmentally beneficial sub-projects that will be financed by the SPPP are subject to case by case assessment soil erosion protection protection of natural and cultural heritage sites

a Consultation and Public Disclosure

25 A simple approach is proposed for public consultation in the early stages of sub-project preparation and planning

The stakeholders should be made aware of the different elements and features of each sub-project and their main objectives and target groups Once an ESIA has been made the results of this study should be disclosed to all concerned primary stakeholders

The stakeholders should then be encouraged to share their concerns worries and any comments they have on the sub-project or its likely impacts This should include discussions on alternative and proposed mitigation measures that are to be accounted for in the sub-project design implementation and operation phases

The final step is to incorporate the stakeholder inputs into the sub-project plans in order to improve the sub-project design

26 The process of stakeholder involvement and consultation will continue during sub-project implementation as well in order to integrate any additional comments and worries that may arise from the construction and implementation phase

27 Consultation with the stakeholders may take different forms depending on the need and subject matter that is being communicated An informative method would be through the use of one-way communication techniques such as audio (radio) visual (television) printed (leaflets brochures pictures diagrams posters) or electronic media (internet and electronic mail) In this case the stakeholders will be merely informed with certain information and there shall be no opportunity for questions or comments In order to have interactive consultation with the

17

stakeholders two-way participatory techniques are required This may include one-to-one briefings small group and village meetings and the organization of workshops and forums

28 The technique used for the disclosure and dissemination of information and data should take into consideration stakeholder preferences and characteristics The disclosed information should be in a language that all stakeholders are familiar with and for those who are illiterate certain measures may need to be taken to ensure that they are fully aware of the contents of the disclosed documents Another important consideration is that ample time should be given to the stakeholders to review the disclosed information prior to the consultation process to allow them to thoroughly address the sub-projects various issues

29 The SPPP will also generate environmental benefits through a variety of other mechanisms among which are

(a)- Generation of environmental assessment guidelines that can be used by other organizations or ministries or could be adopted by the Ministry of Environment for more general use

(b)- Training of environmental specialists thus increasing the number of environmental professionals in the country

(c)- Improved environmental awareness in the local communities

b Future capacity building initiatives

30 These could be done through a structured training along two parallel lines (i) at the level of the implementing agencies when these are guided one by one through the process by the environmental specialist to help them look at the needed assessment and the mitigation measures if any (ii) at the level of the community by organizing awareness campaigns targeted to LCP and other prominent figures and other interested CSOs on environmental issues of relevance and how that affects the sub-projects implemented in their areas That creates a social accountability system that could be used to ensure that the sub-projects are implemented according to appropriate procedures

32 Negative Environmental Impacts

321 Overview of Negative Environmental Impacts

31 The SPPP will finance a considerable number of different types of subprojects An important percentage of the funding will be allocated for social development Though intended to improve environmental and social conditions these subprojects can have a variety of negative environmental impacts that might be encountered during the operation of the subprojects Environmental impacts arising from the operation of the different subprojects can be minimized by appropriate site selection good engineering design and appropriate construction techniques

4 IMPLEMENTATION ARRANGEMENTS

41 Environmental Guidelines

18

32 The implementation of the SPPP falls under the responsibility of MOSA who would be in charge of coordinating the various activities through its Social Development Centers (SDCs) with concerned local governments and NGOs A Project Coordination Team (PCT) will be established and would comprise experts with relevant experience in implementing similar projects and with proven capacity to handle all functions required in such a project Among its mandates the PCT will ensure that any sponsored subproject is environmentally sound and sustainable

33 The PCT shall ensure the following

Environmental considerations will be included as criteria for selecting activities to be supported by the project environmental assessment would become an integral part of the project cycle of any subproject

Environmental guidelines are followed and used throughout the project cycle

Environmental issues are introduced to beneficiaries through education and promotion of environmentally beneficial subprojects

34 The execution of the CSD will be undertaken by Civil Society Organizations (CSO) who would consist of qualified local authorities or national NGOs with strong community ties and proven execution capacity The SDC would assist local NGOs LCF and communities in identifying local needs preparing subprojects coordinating with concerned ministries and implementing the subprojects

42 Environmental Assessment (EA)

35 The World Bank Operational Policy (OP 401) on Environmental Assessment (January 1999) defines the Bankrsquos environmental assessment requirements to ensure that funded sub-projects are environmentally sound and sustainable A screening process is undertaken for all funded sub-projects to assess the magnitude and adversity of predicted environmental impacts and to determine the appropriate extent and type of EA Depending on the type location sensitivity and scale of the project as well as the nature and magnitude of environmental impacts sub-projects are classified into one of three categories

(a)- Category A Sub-Projects that are likely to cause significant and possibly irremediable environmental impacts

(b)- Category B Sub-Projects that might cause lesser adverse impacts than those of Category A and the impacts are often remediable or could be mitigated for

(c)- Category C Sub-Projects which could have minimal or no adverse environmental impacts

19

36 The SPPP will only fund sub-projects that can be classified as either Category B or Category C only For instance all income enhancement sub-projects will be classified as Category C while most social sub-projects will be Category B Sub-projects that are likely to cause substantial negative impacts and are expected to fall in Category A will not be approved for funding

37 This document will provide guidance with respect to the preparation of environmental assessment for the various funded subprojects These guidelines are based on the World Bank Operational Policies (OP 401) the Environmental Assessment Source book (1991) and its updates in addition to the Decree 86332012 on EA issued by the GOL

5 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

51 Objectives and Structure of the ESMP

38 The objectives of the ESMP are to mitigate the adverse environmental impacts identified in the SPPP The ESMP will consist of three kinds of activities

o Implementation of mitigation measures o Strengthening the capacities of PCT SDCs and local NGOs o Monitoring and evaluation of mitigation measures identified during subproject

formulation or within the environmental assessment report

52 Implementation of Mitigation Measures

39 Mitigation measures identified (Table 1) are for typical sub-projects and MOSAPCT will ensure that such measures are adhered to during the overall implementation of the SPPP

Table 1 Potential Environmental Impacts and Proposed Mitigation Measures for Different Subprojects

Project Component

Potential Impacts Mitigation Measures Responsibility

Roads rehabilitation

Clogging of natural drainage channelsEncroachment on private property

Dumping of construction wastes and accidental spills of machine fuels etcRisk of damage to unknown archaeological sites

Maintain ditches

Detailed property boundary surveys and flagging in fieldProper disposal of construction wastes

Use ldquochance findrdquo procedures and coordinate with appropriate

Contractor

ContractorIA

Contractor

IAsArcheology department

20

government agency

Rehabilitation of schools

Rehabilitation of health clinics

Irrigation and drainage

Improper disposal of wastes

Water quality degradation in ponds and reservoirsClogging of canals from weedssedimentsInefficient water flow because of heavy sedimentation

Degradation of water systems receiving irrigation waters by nutrients agrochemical and salts

Proper disposal of solid wastesPriority given to rehabilitation of toiletsInstallation of sanitation (cesspools)

Containerize infectious wastesPublic health awareness

Monitoring of water qualityOperation amp maintenance planProper design of canals and provision of access for weed and sediments removal

Control of agrochemical use

IAsMunicipality

IAscommunity

IAscommunity

Ministry of Health

Ministry of Energy and Water

IAs community

ContractorIAs

Ministry of Agriculturecommunity

53 Training Program and Capacity Building

40 The MOSA lacks the capacities and the expertise to work in the field of environmental monitoring and protection Moreover it is expected that the IAs mostly CSOs and SDCs do not have the needed resources to undertake the requirements needed in terms of EAs and designing mitigation measures This would require a detailed capacity building program that targets all levels of the decision making process in the project The central team at the MOSA and the PCT need to be oriented to the general approach to environmental safeguards importance use and how that could affect the selection implementation and monitoring of Sub-projects SDFCs and IAs should be trained on

21

the technical aspects of detection and mitigation and how these could be imbedded within the process of project identification to formulation to implementation These safeguards will have to be an integral part of any sub-project proposal and consequently any detailed action plan for any specific sub-project Environmental expertise within the implementing and executing bodies will be strengthened Training programs will designed and implemented with the assistance of a local or international expert and will target levels as stated in the Table 2 page 20

41 PCT and IAs At the initiation of the CSD and prior to bidding and selection of IAs a workshop will be provided and will include an environmental session to raise environmental awareness and to clarify the specific environmental requirements related to design and implementation of the SPPP

42 Another training workshop will be provided to the PCT and selected IAs and will cover the following to IAs

EIA techniques Screening sub-projects for environmental review Use of practical formschecklists Best environmental practices in design and implementation of projects Effective implementation of mitigation measures Project supervision Monitoring and evaluation

43 Local NGOs and Contractors IAs will be required to provide workshops for local NGOs and contractors focusing on public awareness case studies of environmental issues experienced in similar projects use of environmental guidelines and implementation of mitigation measures (Table 2 Annex III)

22

Table 2 Training and Capacity Building Program for Implementing the ESAFTraining

Capacity BuildingParticipating Stakeholders

Skills acquired Scheduling Cost Source

ManagementInstitutional

1year

SPPP manager MOSA central unit Head of concerned

departments at MOSA PCT

Decision making and delegation Work procedures Environmental awareness National guidelines WB guidelines Classification and mitigation

Prior to sub-project preparation Planning phase Refresher every 3 months as we

go along the project

Undertaken by the Environmental

SpecialistMiscellaneous

7500 USD

WBMOSA

Institutional at Intermediate levels

2 training sessions of 2 days year

(for SDC and IA X5 regions)

PCT Emanating committee SDC managers IAs

Environmental and social policies

Laws and regulations GOL and WB safeguards Evaluation and selection

During sub-project preparation Planning phase Sub-project evaluation

Undertaken by the Environmental

SpecialistMiscellaneous

30000 USD

WB MOSA

Implementation1 day session X2 year X 5 regions

IAs SDC staff Beneficiaries Municipalities

Environment and social tools Screening amp monitoring

methods Sustainability of the process Practical mitigation and

safeguards

During sub-project preparation Mobilization Implementation

Undertaken by the Environmental

SpecialistMiscellaneous

50000 USD

WB MOSA

Monitoring Evaluation and

Reporting1 dayX2 year X5

regions

IAs SDC staff Beneficiaries

Municipalities

Environmental and social monitoring and compliance

Progress report preparation Monitoring and Evaluation

During sub-project preparation MobilizationImplementation

Environmental Specialist + consultant

50000 USD

WB MOSA

Total 137500 USD (includes in kind contribution from MOSA)

23

54 Environmental Monitoring

44 Environmental Monitoring will be the responsibility of the ES PCT and MOSA Central Unit with the supervision of the LCP and will include compliance monitoring during implementation and also monitoring of significant impacts during the operation of the subproject

Table 3 Typical Examples of Monitoring Plan for the Operation of Different Subprojects

Sub-project Monitoring Indicators Responsibility FrequencyRoads rehabilitation

Operating drainage channels

NGOs in close coordination with local community

Semi-annual assessment

Improvements to Water Supply and Sanitation Facilities

Irrigation and drainage

Distribution network without leaksNo leakage or overflows of manholes or drainsWater Quality Monitoring

Irrigation network without leaksDrainage channels clean and properly maintainedWater quality parameters (pH COD BOD SS)

NGOs in close coordination with local community

Ministry of Health and Ministry of Energy and Water

NGOs in close coordination with local community

Testing by Ministry of Health and Ministry of Energy and Water

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Rehabilitation of schools

Rehabilitation of health clinics

Toilet facilities clean and functioning properlyDrinking water faucets clean and safe from contamination

NGOs in close coordination with local community and appropriate municipality

Ministry of Health in close coordination with local community

Semi-annual assessment

Semi-annual assessment

23

24

45 The Environmental Specialist (ES) of the PCT will also conduct periodic monitoring by visiting the sites of the various sub-projects at least twice during the implementation period of the sub-project

46 Monitoring indicators shall be developed for both the mobilization and the operation phase of the subprojects Monitoring of activities will have to ensure that mitigation measures of operations impacts are being implemented properly while the monitoring of operation is to ensure that no unforeseen negative impacts are arising

55 Sub-project Cycle

47 Component 2 of the SPPP is the Community Social Development Program (CSD) which will be financing community-based sub-projects through grants The Program will have two windows one for social services whereas the other is for Income Generation Activities (IGA) support with the review and approval mechanisms in large part being the same for both windows While Component 3 focuses on Poverty Targeting thus the services provided will have no impact on the environment component 1 will focus on the provision of technology and training to SDCs

48 Applicants will be invited to use standard forms (available on the MOSA website and upon request from SDCs) to submit proposals to the relevant SDC in cases where the applicant is the SDC itself the application will be submitted directly to the CSD program team in Beirut

49 SDCs will immediately check all proposals for completeness and give a receipt to the applicant with a proposal number proposals found to be incomplete will be rejected with an explanation All complete proposals will be presented for discussion to the relevant Local Community Platform (LCP) or equivalent consultative body to obtain feedback on among other things the actual need (in case of social services) or likely market value (in the case of IGA) of the proposed activity the reputation of the applicant the likely sustainability of the proposed activity the preliminary classification of the project within environmental categories (the final classification will be pending on the decision of the environmental specialist within the PCT) any problematic aspect (conflict of interest etc) and the overall compliance of the proposal with the purposes of the program This feedback is not binding but will be taken into consideration when deciding whether or not to fund the proposal The CSD program team will carry out a detailed desk review of all complete proposals to assess their technical quality as well as the budget and time line suggested for the sub-project The environmental specialist member of the Project Coordinating Team (PCT) will review the proposal and prepare all needed documentation based on his classification of the sub-project

56 Screening of Sub-Projects

50 Each sub-project to be implemented by an IA will be subjected to an environmental screening Using the screening form (Form 1) environmental and social checklists for the proposed sub-projects will be screened by the environmental specialist to identify any potential adverse impacts

25

From an environmental standpoint the screening form may identify impacts form sub-projects the issue of solid waste disposal at the site of a sub-project may come out as a point to look at in terms of designing mitigation measures to avoid negative impacts The selection of adequate storage collection and proper disposal could be steps to consider carefully

57 The Environmental and Social Screening Process

51 The objectives of sub-project screening is to determine which activities are likely to have negative environmental and social impacts

571 Subproject Screening Procedures

52 The sub-projects funded under this project are generally categorized as Category B or C and screening mechanisms would ensure that any identified Category A sub-projects are not funded under the project Due to the fact that most Category B sub-projects are small-scale which do not result in adverse negative environmental impacts this will require an ESMP which has clear due diligence environmental and social procedures (including the setting out of institutional responsibilities timing and budget) for sub-projects The ESMP should take into consideration the applicable requirements under the Bankrsquos ten safeguard policies

572 Environmental Sub-Project Screening Checklistsforms

53 The Operation Manual (OM) should contain for each type of sub-project a simple environmental screening checklist (Form 1)) which poses a series of questions designed to identify risks to the environment The goal of the checklist (also called a screening or environmental data sheet) is to identify which sub-projects require more environmental information in the form of a site-specific ESMP or which can proceed without any special mitigation measures that is falling under category C

Form 1 Environmental Screening Check-list

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

4

573 Assign Environmental Categories 28574 Carrying Out Environmental Work 28575 Review and Approval 28576 Monitoring and Follow Up 29577 Monitoring Indicators 29

58 Staffing amp Capacities of MOSA in Environmental Safeguards 29

6 ENVIRONMENTAL REVIEW PROCEDURES amp GUIDELINES61 Status of the SPPP Environmental Review 3262 Institutional Arrangement 3263 Program Cycle 3364 Promotion of sub-projects 3465 Formulation of Sub-projects 3466 Appraisal amp Approval of Proposed Programs 3567 Implementation amp Monitoring 35

ANNEXES

ANNEX I PRIMARY OBJECTIVES OF MITIGATION MEASURES 36ANNEX II ENVIRONMENTAL FRAMEWORK IN LEBANON 37ANNEXIII TERMS OF REFERENCE FOR THE PREPARATION OF THE

ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)43

Table 1 ESMP TEMPLATES (MITIGATION MEASURES) 47Table 2 ESMP TEMPLATES (TRAINING amp CAPACITY BUILDING) 48Table 3 ESMP TEMPLATES (MONITORING) 49

ANNEX IV PUBLIC CONSULTATION 50

5

EXECUTIVE SUMMARY

This Report has been prepared to present the environmental requirements and guidelines for the Social Promotion and Protection Project (SPPP) that the Government of Lebanon is planning to initiate through the Ministry of Social Affairs (MOSA)

Project DescriptionThe project consists of three components (i) developing the role and capacity of Social Development Centers (SDCs) (ii) establishing and supporting an effective national program in MOSA to finance community developed and driven projects and (iii) continued roll-out and institutionalization of the National Poverty Targeting Program (NPTP)

This Environmental Social Assessment Framework (ESAF) is designed to ensure protection of the health and livelihood of beneficiaries and the environment The framework is intended to protect against both local impacts of individual subprojects and the cumulative impact of many similar subprojects in the same area

Many subprojects have little or no adverse impact However it is important to acknowledge possible unfavorable effects Experience shows that CDD projects need to establish simple social and environmental assessment procedures to avoid causing adverse harm to human health and the environment

The main elements of the Environmental Social Assessment Framework are (1) Tools These tools usually include guidance written in the local language and presented in a form easily understood by community facilitators (2)Implementation Arrangements A description of roles and responsibilities to ensure that the identification avoidance and mitigation of environmental and social risks should be built into sub-project preparation appraisal and supervision (3) Capacity Building Training must be provided to ensure that every person with a role in the safeguard implementation arrangements is able to fulfill their responsibilities (4) Supervision and Monitoring Arrangements should be in place to supervise both the adequacy and application of the safeguard management tools (5) Audit During preparation of the program it is useful to agree that an independent audit of the Safeguards Management Framework will be undertaken at mid-term to draw lessons and recommend improvements

The implementation of the SPPP falls under the responsibility of MOSA who would be in charge of coordinating the various activities through its Social Development Centers (SDC) with concerned local governments and NGOs A Project Coordination Team (PCT) will be established and would comprise experts with relevant experience in implementing similar projects and with proven capacity to handle all functions required in such a project Among its mandates the PCT will ensure that any sponsored subproject is environmentally sound and sustainableThe World Bank Operational Policy (OP 401) on Environmental Assessment (January 1999) defines the Bankrsquos environmental assessment requirements to ensure that funded projects are

6

environmentally sound and sustainable A screening process is undertaken for all funded projects to assess the magnitude and adversity of predicted environmental impacts and to determine the appropriate extent and type of EA Depending on the type location sensitivity and scale of the project as well as the nature and magnitude of environmental impacts projects are classified into one of three categories

(a)- Category A Projects that are likely to cause significant and possibly irremediable environmental impacts

(b)- Category B Projects that might cause lesser adverse impacts than those of Category A and the impacts are often remediable or mitigable

(c)- Category C Projects which could have minimal or no adverse environmental impacts

Subprojects funded by the SPPP are classified as Category B or Category C Sub-projects found to be category A as per World Bank environmental safeguards classification will not be funded by the project

Following this division sub-projects falling only under categories B will need Environmental and Social Management Plans (ESMPs) to be prepared and reviewed for clearance prior to providing final approval for the sub-project

This document describes the needed step and tools that need to be looked at in the design of the sub-project as well as the mitigation measures needed for implementation that takes into account all environmental and social considerations and thus mitigates for any negative impacts in this regard

7

1 INTRODUCTION

11 Background

This document constitutes an integral part of the Project Appraisal Document intended for a World Bank loan to the Government of Lebanon at a total value of USD 30 Million for the implementation of the Social Promotion and Protection Project (SPPP) It has been prepared to present the environmental requirements and guidelines for the SPPP that the Government of Lebanon is planning to initiate through the Ministry of Social Affairs (MOSA)

PROJECT DEVELOPMENT OBJECTIVES

A Project Development Objective

1 The development objective of SPPP is to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

Project Beneficiaries

2 The SPPP beneficiaries consist of the following three categories

(a) Poor and Vulnerable Households and Community Members The ultimate beneficiaries of the project include (a) vulnerable individuals and households (eg children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) who will have improved access to social services provided by SDCs (b) poor and vulnerable individuals who will receive assistance through income generating activities (IGAs) as well as others in the community who will find new employment or experience increased earnings stimulated by growth of IGAs and (c) the poor households who will be eligible to receive NPTP benefits

(b) MOSA The project will help strengthen MOSArsquos capacity to carry out its official mandate both at the central level and through the SDCs at the local levels In particular MOSA will be supported in managing the implementation of small projects using a community-based demand-driven and participatory approach so as to position itself as the main government actor for community development activities in the social sphere At the same time the continued implementation of the NPTP will help MOSA develop the skills needed for administering well-targeted and efficient social safety nets

(c) Civil Society Organizations (CSOs) CSOs will also benefit from the project as they will have an opportunity to improve their capacity to propose prepare and implement income-generating projects and social services at the community level

8

B Project Components

3 The SPPP will have the following four components (1) Social Development Centers (SDCs) (2) Community Social Development Program (CSD) (3) National Poverty Targeting Program (NPTP) and (4) Project Coordination Team (PCT) Component 1 which focuses on building the capacity of the SDCs is cross-cutting between Components 2 and 3 as the SDCs are the local implementing arms of MOSArsquos mandate Specifically both the CSD and NPTP programs rely on the SDCs for implementation

Component 1 Social Development Centers (SDCs) (US$952 million total cost of which US$908 million to be financed from the loan)

4 The objective of this component is to enhance the administrative and operational capacity of the SDCs to enable them to offer social services of improved quality and relevance This component will also include key cross-component functions such as monitoring and evaluation social accountability measures and communication outreach To achieve the above this component will consist of the following sub-components

(a) Equipping automating and electronically linking the SDCs to the central unit at MOSA The project will finance (i) necessary equipment and software to computerize systems and processes at the SDCs (eg creating databases) and to ensure proper processing of NPTP transactions (ii) the establishment of a computerized modular MIS with dedicated modules for the CSD and NPTP1 programs as well as for other core functions (eg procurement financial management) and accessible to both SDCs and the central MOSA unit (iii) internet connectivity between the SDCs and MOSA and (iv) small works and equipment to refurbish and rehabilitate the SDCs as needed

(b) Building and empowering the human resources of the SDCs The project will finance training of SDC staff including in (i) the use of new equipment and systems (ii) specific topics to support the implementation of the CSD and NPTP programs such as handling grievances writing proposals and applying case management and participatory approaches

(c) Community participation The project will finance capacity building and technical assistance for SDCs to (i) establish mechanisms at the SDC level to facilitate community consultation in the SDC catchment area in the form of ldquoLocal Consultative Platformsrdquo (LCP) and (ii) create inventories of local social service providers carry out social needs assessments and prioritization and establish referral systems to ensure that social services match community needs

(d) Monitoring and Evaluation Social Audits and Communication Outreach (see Section IV B for further details) The project will finance the development of a comprehensive MampE system relying primarily on the computerized MIS as well as training of MOSA staff and the project team to use it This will include assessing the performance of the present NPTP MampE system improving it as needed and

1 As an NPTP module is already in use any needed upgrading will be handled under the NPTP Component

9

carrying out short surveys on a regular basis (eg opinion polls) As part of the monitoring effort as well as to promote good governance this component will finance social audits Communication outreach campaigns for the NPTP and the CSD programs will also be supported

Component 2 Community Social Development Program (CSD) (US$1729 million total cost of which US$1232 million to be financed from the loan)

5 This component aims to establish a transparent accountable and efficient national CSD program that will finance community-based sub-projects through grants The CSD program is designed building on the experience of the World Bank-supported Community Development Project (2001-2008) MOSA experiences as well as lessons learnt from other CDD programs in Lebanon and around the world Grant sizes are limited to US$50000 equivalent implementation time for each sub-grant is one year and beneficiaries will be required to make contributions upfront Targeting will be done according to two criteria (a) geographic targeting to prioritize areas of greater poverty and deprivation (eg Akkar district) based on information from updated poverty estimates and studies carried out by various donors (eg the European Union) and (b) categorical targeting to prioritize vulnerable groups (eg the handicapped) based on MOSArsquos mandate The component will consist of the following two sub-components

(a) Establishment of a National Community Social Development Program in MOSA the project will finance technical assistance in the form of key experts (eg CSD program manager engineer social specialist income-generating specialist) who will manage a transparent process of calls for proposals screening and prioritization of proposals and monitoring and supervision of sub-grant implementation

(b) Funding community-driven sub-projects The project will provide grants to eligible applicants (primarily SDCs and CSO) whose projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

10

Component 3 National Poverty Targeting Program (NPTP) (US$17286 million total cost of which US$665 million to be financed from the loan)

6 This component aims to expand the coverage from approximately 100300 (expected in 2013 baseline of SPPP) to 238700 (in 2018) individual beneficiaries as well as to improve the efficiency of the NPTP To achieve this objective the project will provide technical support for the continued roll-out and institutionalization of the NPTP which was launched in 2011 under the Bank-financed Second Emergency Social Protection Implementation Support Project (ESPISP II) Presently NPTP benefits consist of waived school and hospitalization fees coverage of chronic disease medications free schoolbooks and discounts on electricity bills The cost of these benefits as well as that of the SDC social workers involved in administering the program are being borne and will continue to be borne by the Government2 To achieve its objective this component will consist of the following three sub-components

(a) Continued roll-out and institutionalization The project will finance technical assistance for (i) supporting the program management team (ii) refining the program application forms and Proxy-Mean Testing (PMT) questionnaire (iii) upgrading the MIS module for the NPTP and establishing an archiving system (iv) adopting measures to prevent and discourage fraud and corruption (v) refining the grievance and redress mechanism for improved efficiency and transparency

(b) Access to social safety nets The project will finance technical assistance for (i) assessing the performance of the reimbursement mechanism of the NPTP benefits and designing any improvements and (ii) designing and piloting a case management approach with NPTP beneficiary households

(c) Enabling evidence-based policy making for poverty reduction The project will finance (i) technical assistance to support the Inter-ministerial Committee for Social Policy (Social-IMC) and its Secretariat (ii) technical assistance to establish a Poverty Analysis Team whose role will be to assess the poverty and inequality situation in Lebanon using Household Budget Survey (HBS) data and (iii) the design and implementation of the next HBS (in 2017) which will be a large-sample survey representative at the governorate (mohafazat) level

Component 4 Project Coordination Team (PCT) (US$214 million out of which US$195 from the loan)

7 The project will finance a team who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components (see Section III and Annex IV of the Project Appraisal Document) reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively

2 The Council of Ministers allocated US$28 million in 2011 to finance the benefits and approximately US$4 million for the hiring of 350 social workers

11

contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management

12 IMPLEMENTATION

a Institutional and Implementation Arrangements

8 MOSA is the project implementing agency and it will oversee the implementation of all SPPP activities A Project Coordinator will head the PCT and also be responsible for the implementation of Component 1 assisted by a Project Officer while Components 2 and 3 will each be headed by a Program Manager These positions will be financed by project funds A combination of contracted and MOSA staff will be responsible for the implementation of component activities

9 Each component will be overseen by a MOSA committee that will report to the Minister In the case of Components 2 and 3 the committee will be an ldquoEmanating Project Committeerdquo3 which will check the legal aspect of all activities financed and implemented by the component (which is considered an ldquoemanating projectrdquo) and oversee the way the funds are being spent In the case of Component 1 the committee will be a SDC Committee consisting of the SDC Director and other MOSA staff4

10 The heads of the components and the MOSA Minister (as well as the Director General if the position is filled) will form the SPPP Steering Committee which will meet periodically to review implementation progress and ensure coherence with ministry policies At the national policy level the Social Inter-Ministerial Committee (Social-IMC) with MOSA acting as its Technical Secretariat will ensure coordination of the SPPP with other social policies5 Further details are provided in Annex 3 of the Loan Agreement

11 With respect to the institutional setup of the NPTP the program has been operating under a ldquodual managementrdquo by MOSA and the Presidency of the Council of Ministers (PCM)6 This was deemed the best option at the time of appraisal of the ESPISP II project which supported the

3Emanating Project Committees are established as a way to circumvent the cumbersome Lebanese bureaucracy while still providing appropriate oversight They generally comprise five or six members taken from high-ranking positions within the Ministry (eg Department Directors)4 Each SDC has its own Emanating Committee so it would not be possible to also have an Emanating Committee overseeing the component5The Social-IMC established on January 22 2007 by a decree signed by the Prime Minister and composed of the Ministers of Finance Social Affairs Health Education Labor Interior amp Municipal Affairs Economy amp Trade NSSF and the President of CDR is charged with (i) drafting a comprehensive integrated and coordinated social strategy (ii) coordinating government activities for the provisions of social services (iii) ensuring coordination of all studies surveys reports related to social affairs and ensuring availability of relevant social data and indicators (iv) overseeing the implementation of social safety net programs and (v) coordinating monitoring and evaluating development programs that are financed by local and international partners6 This dual management consists of a central management unit at the PCM and Management central unit in MOSA The former is responsible for (i) co-managing the central NPTP database (ii) validating data and cross-checking with national databases (iii) processing household data and generating scores and ranks according to the proxy-means testing (PMT) formula (iv) maintaining the PMT formula (v) analyzing national data and reporting findings to the Social Inter-Ministerial Committee (Social-IMC) (vi) monitoring the NPTP targeting and (vii) auditing data processing The central unit in MOSA (through its SDCs)is responsible for (i) co-managing the central NPTP database (ii) receiving household applications (iii) interfacing with applicants (iv) entering data (v) conducting household visits (vi) checking for data errors (vii) transmitting data to the central database of the NPTP CMU and (viii) managing the public relations campaign

12

creation of the NPTP7 The present institutional setup will be retained during the implementation of the SPPP though the GOL has started discussing the possibility of consolidating the NPTP under MOSA and institutionalizing it as an independent program with its own budgetary allocations

This document is intended to look at designing the Environmental and Social Assessment Framework (ESAF) for the sub-projects to be financed under Component 2 of the SPPP

b Purpose of the Environmental and Social Assessment Framework (ESAF)

12 The ESAF is designed to ensure protection of the health and livelihood of beneficiaries and the environment The framework is intended to protect against both local impacts of individual sub-projects and the cumulative impact of many similar subprojects in the same area

13 Although many sub-projects have little or no adverse impact it is important nonetheless to acknowledge the possible unfavorable effects Experience shows that CDD projects need to establish simple social and environmental assessment procedures to avoid causing adverse harm to human health and the environment

14 The main elements of the Environmental and Social Assessment Framework (ESAF)are described below

Tools These tools usually include guidance written in the local language and presented in a form easily understood by community facilitators as well as

(i) rules-based social and environmental criteria establishing basic dorsquos and donrsquots and indicating the permissions and clearances required for common activities and(ii) mitigation guidelines providing practical guidance for the avoidance or mitigation of potential environmental impacts and identifying issues for which more specific expert guidance should be sought

Implementation Arrangements A description of roles and responsibilities to ensure that the identification avoidance and mitigation of environmental and social risks should be built into sub-project preparation appraisal and supervision This normally includes roles at the levels of community facilitators local management and program-wide management These should also be reflected in any Operational Manual that is prepared This description should abide by the rules and regulations issued by the Ministry of Environment

Capacity Building Training must be provided to ensure that every person with a role in the safeguard implementation arrangements is able to fulfill their responsibilities It is important that training in environmental and social safeguards management is incorporated from the very start of the program before the preparation of sub-projects begins

Supervision and Monitoring Arrangements should be in place to supervise both the adequacy and application of the safeguard management tools In addition it is useful to keep track of environmental concerns in program areas so that more specific mitigation measures can be

7Other options were considered at the time and are detailed in the EPP of the ESPISP II

13

designed and opportunities for enhancements can be promoted Secondary information gathering is usually sufficient for this purpose

Audit During preparation of the program it is useful to agree that an independent audit of the ESAF will be undertaken at mid-term to draw lessons and recommend improvements

15 Experience has shown the value of involving environmental organizations particularly those with advocacy expertise in the design of the Environmental and Social Assessment Frameworks and subsequently in the associated capacity building supervision and monitoring This in fact was done through the consultation process as it will be documented in later sections of this document Access to environmental expertise can be facilitated during program implementation through the identification of local professionals with an environmental background who can form a resource pool to be mobilized locally as subprojects require

16 Social funds and CDD programs also provide important opportunities to promote pro-poor reforms in environmental policies particularly those associated with access to natural resources and their management The involvement of national and local environmental specialists can play a valuable role in advancing these agendas

17 A development project mitigation measures (Annex I) encompass all actions taken to eliminate offset or reduce potentially adverse environmental impacts to acceptable levels Such measures are typically associated with the latter stages of project planning although in practice they may occur at any stage throughout the project cycle Normally potential impacts are identified early during the initiation and scoping stages of EA for a project and measures to avoid or minimize impacts are incorporated into the alternatives being considered In this respect some of the most important measures to protect the environment or local communities become integral to the project design and are never reflected within a formal environmental and social management plan (ESMP) For example the environmental and social bases for choosing a preferred location for a project will not necessarily be evident within the ESMP

18 Environmental and Social Management Plans (ESMPs) outline the mitigation monitoring and institutional measures to be taken during sub-project implementation and operation to avoid or control adverse environmental impacts and the actions needed to implement these measures They provide a crucial link between alternative mitigation measures evaluated and described within the EA report and ensuring that such measures are implemented EA reports are essentially planning documents with no legal basis In many cases mitigation measures outlined in EAs are described in illustrative terms or have neither been committed to by the borrower nor reflected in the project design In this regard the ESMP is a basis for negotiation and reaching agreement with borrowers on a sub-projectrsquos key social and environmental performance standards

19 This report aims at providing guidance in identifying environmental assessment needs for the various sub-projects that are funded under Component 2 of the SPPP and might have the potential of inflicting environmental impacts that need to be addressedFunded sub-projects fall under two categories

14

(i) Social Development (a) improving access to specialized social services to satisfy the needs of vulnerable groups at risk including the disabled children youth women and the elderly (b) enhancing environmental protection initiatives such as reforestation and soil erosion control wells and spring protection and preservation of natural sites

(ii) Income Enhancement Capacity building activities to support (a) micro and small entrepreneurs and non-governmental organizations providing credit to target beneficiary groups and (b) women youth and disabled people in order to provide them with demand driven specialized skills to improve their income and enhance their business opportunities

2 POLICY LEGAL amp INSTITUTIONAL FRAMEWORK FOR THE ENVIRONMENT

21 Regulatory Framework for Environmental Impact Assessment

20 Presently the environmental framework of Lebanon is managed and supervised by the Ministry of Environment (MOE) that was created by law 216 of April 2nd 1993 to be the government institution responsible for the development of a national strategy for sustainable development This was strengthened through the Law 4442002 Framework Law for the Protection of the Environment and the CEA (Country Environmental Analysis) The MOE is undergoing several review procedures to up-date the countryrsquos environmental policies and regulations including the preparation of an Environmental Code issuance of an Environmental Impact Assessment (EIA) decree as well as norms and standards for environmental protection The Environmental codes as well as the EIA decree were prepared with the assistance of the World Bank under the Mediterranean Environmental Technical Assistance Program (METAP) Also the World Bank has financed through METAP an assessment of the EIA System in Lebanon (Annex II)

METAP has also supported the establishment of an Environmental Management System Unit (EMSU) dealing with EIA at the MOE The concept of EA as part of project planning in Lebanon is still new and has only recently gained some attention The Environmental Impact Assessment (EIA) decree that was prepared by the MOE will require that an EIA be prepared during the planning process of both public and private development projects in Lebanon

22 Existing Environmental Legislation

221 International Conventions

21 The Lebanese Government has ratified a large number of international conventions for Environmental Protection Among the most important ones are

The Barcelona Convention for the protection of the Mediterranean SEA International Convention on World Heritage Protection International Convention on Bio-diversity Protection United Nations Convention on Desertification Montreal Protocol for the protection of the Ozone layer

15

222 Existing Lebanese Legislations

22 A list of the most significant existing environmental legislation is given in Annex II The primary safeguards as they are likely to affect SPPP subprojects are summarized in the following sections

Natural LandscapeProtection of the natural landscape of Lebanon was first addressed under the Law of January 1949 Recently cutting of trees was severely restricted under Decree No142 of March 1993 and further protection was provided under Law No 550 dated July 1996 There are also a number of Laws and Decisions that were issued to protect sites of particularly valuable landscape by declaring them Natural Reserves

Soil Water and Air PollutionProtection against pollution was first addressed by Decree No 8735 of October 1974 that prohibited the digging of wells for the disposal of raw sewage banned infiltration from cesspools and the use of sewage for the irrigation of vegetables and some fruits Decision No 521 of July 1996 introduced measures to deal with the pollution of the air water and soil including national standards for drinking water bathing waters and wastewater quality Recently Decision No 81 dated March 2001completed and reviewed the previously issued standards

Water ResourcesGround and surface water resources have been protected since the introduction of Order No 144 dated June 1925 which covered the major springs that supply the countryrsquos potable and irrigation needs Zoning of water sources and recharging of catchment areas was introduced by Decree 10276 of October 1962 to cope with increasing demand for water In 1970 Decree 14438 established a limit on the depth and exploitation of unlicensed wells and boreholes 150 m and 100 m3d respectively

Archaeological and Historical SitesThe protection of archaeological and historic sites was first addressed in Law No 1666 of November 1933 Later legislation has been introduced to afford special protection to the Cultural Heritage World Heritage and Cultural Landscape Sites declared by UNESCO

Public StreetsLaw No 60 of September 1983 covers Work in public streets law No 98 of September 1989 and by Circular 695 issued by the Prime Ministerrsquos Office on March 1995

Decree 86332012 on EIA describes clearly the various measures that need to be considered in the preliminary Environmental Evaluation of any project Projects found to require further investigation will have to be subjected to an EIA whereby complete set of information is required to allow for the Ministry to suggest needed mitigation measures and issue accordingly needed permits The stipulations of the decree go in hand with most of the WB guidelines The decree describes the various categories of sub-projects that do

16

require EIA and what are the projects that might cause risks and hazards A copy of the decree will be attached as an Annex to this document

23 Permit Procedures

23 Depending on the type and size of the sub-project to be executed and according to the Lebanese legislation a number of approvals and permits might be required from various governmental agencies In view of their nature and scale the majority of the sub-projects that would be funded by the SPPP will only require the approval of the municipality and or the Ministry of Municipalities and Rural Affairs

3 POTENTIAL SIGNIFICANT ENVIRONMENTAL IMPACTS AND GOOD PRACTICE MITIGATION PROCEDURES

31 Positive Environnemental Impact

24 Most sub-projects financed by the SPPP that are well designed and properly implemented can have a positive impact on the environment The benefits of this type of sub-projects are often long term rather than short term and are not limited to the specific local community Examples of environmentally beneficial sub-projects that will be financed by the SPPP are subject to case by case assessment soil erosion protection protection of natural and cultural heritage sites

a Consultation and Public Disclosure

25 A simple approach is proposed for public consultation in the early stages of sub-project preparation and planning

The stakeholders should be made aware of the different elements and features of each sub-project and their main objectives and target groups Once an ESIA has been made the results of this study should be disclosed to all concerned primary stakeholders

The stakeholders should then be encouraged to share their concerns worries and any comments they have on the sub-project or its likely impacts This should include discussions on alternative and proposed mitigation measures that are to be accounted for in the sub-project design implementation and operation phases

The final step is to incorporate the stakeholder inputs into the sub-project plans in order to improve the sub-project design

26 The process of stakeholder involvement and consultation will continue during sub-project implementation as well in order to integrate any additional comments and worries that may arise from the construction and implementation phase

27 Consultation with the stakeholders may take different forms depending on the need and subject matter that is being communicated An informative method would be through the use of one-way communication techniques such as audio (radio) visual (television) printed (leaflets brochures pictures diagrams posters) or electronic media (internet and electronic mail) In this case the stakeholders will be merely informed with certain information and there shall be no opportunity for questions or comments In order to have interactive consultation with the

17

stakeholders two-way participatory techniques are required This may include one-to-one briefings small group and village meetings and the organization of workshops and forums

28 The technique used for the disclosure and dissemination of information and data should take into consideration stakeholder preferences and characteristics The disclosed information should be in a language that all stakeholders are familiar with and for those who are illiterate certain measures may need to be taken to ensure that they are fully aware of the contents of the disclosed documents Another important consideration is that ample time should be given to the stakeholders to review the disclosed information prior to the consultation process to allow them to thoroughly address the sub-projects various issues

29 The SPPP will also generate environmental benefits through a variety of other mechanisms among which are

(a)- Generation of environmental assessment guidelines that can be used by other organizations or ministries or could be adopted by the Ministry of Environment for more general use

(b)- Training of environmental specialists thus increasing the number of environmental professionals in the country

(c)- Improved environmental awareness in the local communities

b Future capacity building initiatives

30 These could be done through a structured training along two parallel lines (i) at the level of the implementing agencies when these are guided one by one through the process by the environmental specialist to help them look at the needed assessment and the mitigation measures if any (ii) at the level of the community by organizing awareness campaigns targeted to LCP and other prominent figures and other interested CSOs on environmental issues of relevance and how that affects the sub-projects implemented in their areas That creates a social accountability system that could be used to ensure that the sub-projects are implemented according to appropriate procedures

32 Negative Environmental Impacts

321 Overview of Negative Environmental Impacts

31 The SPPP will finance a considerable number of different types of subprojects An important percentage of the funding will be allocated for social development Though intended to improve environmental and social conditions these subprojects can have a variety of negative environmental impacts that might be encountered during the operation of the subprojects Environmental impacts arising from the operation of the different subprojects can be minimized by appropriate site selection good engineering design and appropriate construction techniques

4 IMPLEMENTATION ARRANGEMENTS

41 Environmental Guidelines

18

32 The implementation of the SPPP falls under the responsibility of MOSA who would be in charge of coordinating the various activities through its Social Development Centers (SDCs) with concerned local governments and NGOs A Project Coordination Team (PCT) will be established and would comprise experts with relevant experience in implementing similar projects and with proven capacity to handle all functions required in such a project Among its mandates the PCT will ensure that any sponsored subproject is environmentally sound and sustainable

33 The PCT shall ensure the following

Environmental considerations will be included as criteria for selecting activities to be supported by the project environmental assessment would become an integral part of the project cycle of any subproject

Environmental guidelines are followed and used throughout the project cycle

Environmental issues are introduced to beneficiaries through education and promotion of environmentally beneficial subprojects

34 The execution of the CSD will be undertaken by Civil Society Organizations (CSO) who would consist of qualified local authorities or national NGOs with strong community ties and proven execution capacity The SDC would assist local NGOs LCF and communities in identifying local needs preparing subprojects coordinating with concerned ministries and implementing the subprojects

42 Environmental Assessment (EA)

35 The World Bank Operational Policy (OP 401) on Environmental Assessment (January 1999) defines the Bankrsquos environmental assessment requirements to ensure that funded sub-projects are environmentally sound and sustainable A screening process is undertaken for all funded sub-projects to assess the magnitude and adversity of predicted environmental impacts and to determine the appropriate extent and type of EA Depending on the type location sensitivity and scale of the project as well as the nature and magnitude of environmental impacts sub-projects are classified into one of three categories

(a)- Category A Sub-Projects that are likely to cause significant and possibly irremediable environmental impacts

(b)- Category B Sub-Projects that might cause lesser adverse impacts than those of Category A and the impacts are often remediable or could be mitigated for

(c)- Category C Sub-Projects which could have minimal or no adverse environmental impacts

19

36 The SPPP will only fund sub-projects that can be classified as either Category B or Category C only For instance all income enhancement sub-projects will be classified as Category C while most social sub-projects will be Category B Sub-projects that are likely to cause substantial negative impacts and are expected to fall in Category A will not be approved for funding

37 This document will provide guidance with respect to the preparation of environmental assessment for the various funded subprojects These guidelines are based on the World Bank Operational Policies (OP 401) the Environmental Assessment Source book (1991) and its updates in addition to the Decree 86332012 on EA issued by the GOL

5 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

51 Objectives and Structure of the ESMP

38 The objectives of the ESMP are to mitigate the adverse environmental impacts identified in the SPPP The ESMP will consist of three kinds of activities

o Implementation of mitigation measures o Strengthening the capacities of PCT SDCs and local NGOs o Monitoring and evaluation of mitigation measures identified during subproject

formulation or within the environmental assessment report

52 Implementation of Mitigation Measures

39 Mitigation measures identified (Table 1) are for typical sub-projects and MOSAPCT will ensure that such measures are adhered to during the overall implementation of the SPPP

Table 1 Potential Environmental Impacts and Proposed Mitigation Measures for Different Subprojects

Project Component

Potential Impacts Mitigation Measures Responsibility

Roads rehabilitation

Clogging of natural drainage channelsEncroachment on private property

Dumping of construction wastes and accidental spills of machine fuels etcRisk of damage to unknown archaeological sites

Maintain ditches

Detailed property boundary surveys and flagging in fieldProper disposal of construction wastes

Use ldquochance findrdquo procedures and coordinate with appropriate

Contractor

ContractorIA

Contractor

IAsArcheology department

20

government agency

Rehabilitation of schools

Rehabilitation of health clinics

Irrigation and drainage

Improper disposal of wastes

Water quality degradation in ponds and reservoirsClogging of canals from weedssedimentsInefficient water flow because of heavy sedimentation

Degradation of water systems receiving irrigation waters by nutrients agrochemical and salts

Proper disposal of solid wastesPriority given to rehabilitation of toiletsInstallation of sanitation (cesspools)

Containerize infectious wastesPublic health awareness

Monitoring of water qualityOperation amp maintenance planProper design of canals and provision of access for weed and sediments removal

Control of agrochemical use

IAsMunicipality

IAscommunity

IAscommunity

Ministry of Health

Ministry of Energy and Water

IAs community

ContractorIAs

Ministry of Agriculturecommunity

53 Training Program and Capacity Building

40 The MOSA lacks the capacities and the expertise to work in the field of environmental monitoring and protection Moreover it is expected that the IAs mostly CSOs and SDCs do not have the needed resources to undertake the requirements needed in terms of EAs and designing mitigation measures This would require a detailed capacity building program that targets all levels of the decision making process in the project The central team at the MOSA and the PCT need to be oriented to the general approach to environmental safeguards importance use and how that could affect the selection implementation and monitoring of Sub-projects SDFCs and IAs should be trained on

21

the technical aspects of detection and mitigation and how these could be imbedded within the process of project identification to formulation to implementation These safeguards will have to be an integral part of any sub-project proposal and consequently any detailed action plan for any specific sub-project Environmental expertise within the implementing and executing bodies will be strengthened Training programs will designed and implemented with the assistance of a local or international expert and will target levels as stated in the Table 2 page 20

41 PCT and IAs At the initiation of the CSD and prior to bidding and selection of IAs a workshop will be provided and will include an environmental session to raise environmental awareness and to clarify the specific environmental requirements related to design and implementation of the SPPP

42 Another training workshop will be provided to the PCT and selected IAs and will cover the following to IAs

EIA techniques Screening sub-projects for environmental review Use of practical formschecklists Best environmental practices in design and implementation of projects Effective implementation of mitigation measures Project supervision Monitoring and evaluation

43 Local NGOs and Contractors IAs will be required to provide workshops for local NGOs and contractors focusing on public awareness case studies of environmental issues experienced in similar projects use of environmental guidelines and implementation of mitigation measures (Table 2 Annex III)

22

Table 2 Training and Capacity Building Program for Implementing the ESAFTraining

Capacity BuildingParticipating Stakeholders

Skills acquired Scheduling Cost Source

ManagementInstitutional

1year

SPPP manager MOSA central unit Head of concerned

departments at MOSA PCT

Decision making and delegation Work procedures Environmental awareness National guidelines WB guidelines Classification and mitigation

Prior to sub-project preparation Planning phase Refresher every 3 months as we

go along the project

Undertaken by the Environmental

SpecialistMiscellaneous

7500 USD

WBMOSA

Institutional at Intermediate levels

2 training sessions of 2 days year

(for SDC and IA X5 regions)

PCT Emanating committee SDC managers IAs

Environmental and social policies

Laws and regulations GOL and WB safeguards Evaluation and selection

During sub-project preparation Planning phase Sub-project evaluation

Undertaken by the Environmental

SpecialistMiscellaneous

30000 USD

WB MOSA

Implementation1 day session X2 year X 5 regions

IAs SDC staff Beneficiaries Municipalities

Environment and social tools Screening amp monitoring

methods Sustainability of the process Practical mitigation and

safeguards

During sub-project preparation Mobilization Implementation

Undertaken by the Environmental

SpecialistMiscellaneous

50000 USD

WB MOSA

Monitoring Evaluation and

Reporting1 dayX2 year X5

regions

IAs SDC staff Beneficiaries

Municipalities

Environmental and social monitoring and compliance

Progress report preparation Monitoring and Evaluation

During sub-project preparation MobilizationImplementation

Environmental Specialist + consultant

50000 USD

WB MOSA

Total 137500 USD (includes in kind contribution from MOSA)

23

54 Environmental Monitoring

44 Environmental Monitoring will be the responsibility of the ES PCT and MOSA Central Unit with the supervision of the LCP and will include compliance monitoring during implementation and also monitoring of significant impacts during the operation of the subproject

Table 3 Typical Examples of Monitoring Plan for the Operation of Different Subprojects

Sub-project Monitoring Indicators Responsibility FrequencyRoads rehabilitation

Operating drainage channels

NGOs in close coordination with local community

Semi-annual assessment

Improvements to Water Supply and Sanitation Facilities

Irrigation and drainage

Distribution network without leaksNo leakage or overflows of manholes or drainsWater Quality Monitoring

Irrigation network without leaksDrainage channels clean and properly maintainedWater quality parameters (pH COD BOD SS)

NGOs in close coordination with local community

Ministry of Health and Ministry of Energy and Water

NGOs in close coordination with local community

Testing by Ministry of Health and Ministry of Energy and Water

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Rehabilitation of schools

Rehabilitation of health clinics

Toilet facilities clean and functioning properlyDrinking water faucets clean and safe from contamination

NGOs in close coordination with local community and appropriate municipality

Ministry of Health in close coordination with local community

Semi-annual assessment

Semi-annual assessment

23

24

45 The Environmental Specialist (ES) of the PCT will also conduct periodic monitoring by visiting the sites of the various sub-projects at least twice during the implementation period of the sub-project

46 Monitoring indicators shall be developed for both the mobilization and the operation phase of the subprojects Monitoring of activities will have to ensure that mitigation measures of operations impacts are being implemented properly while the monitoring of operation is to ensure that no unforeseen negative impacts are arising

55 Sub-project Cycle

47 Component 2 of the SPPP is the Community Social Development Program (CSD) which will be financing community-based sub-projects through grants The Program will have two windows one for social services whereas the other is for Income Generation Activities (IGA) support with the review and approval mechanisms in large part being the same for both windows While Component 3 focuses on Poverty Targeting thus the services provided will have no impact on the environment component 1 will focus on the provision of technology and training to SDCs

48 Applicants will be invited to use standard forms (available on the MOSA website and upon request from SDCs) to submit proposals to the relevant SDC in cases where the applicant is the SDC itself the application will be submitted directly to the CSD program team in Beirut

49 SDCs will immediately check all proposals for completeness and give a receipt to the applicant with a proposal number proposals found to be incomplete will be rejected with an explanation All complete proposals will be presented for discussion to the relevant Local Community Platform (LCP) or equivalent consultative body to obtain feedback on among other things the actual need (in case of social services) or likely market value (in the case of IGA) of the proposed activity the reputation of the applicant the likely sustainability of the proposed activity the preliminary classification of the project within environmental categories (the final classification will be pending on the decision of the environmental specialist within the PCT) any problematic aspect (conflict of interest etc) and the overall compliance of the proposal with the purposes of the program This feedback is not binding but will be taken into consideration when deciding whether or not to fund the proposal The CSD program team will carry out a detailed desk review of all complete proposals to assess their technical quality as well as the budget and time line suggested for the sub-project The environmental specialist member of the Project Coordinating Team (PCT) will review the proposal and prepare all needed documentation based on his classification of the sub-project

56 Screening of Sub-Projects

50 Each sub-project to be implemented by an IA will be subjected to an environmental screening Using the screening form (Form 1) environmental and social checklists for the proposed sub-projects will be screened by the environmental specialist to identify any potential adverse impacts

25

From an environmental standpoint the screening form may identify impacts form sub-projects the issue of solid waste disposal at the site of a sub-project may come out as a point to look at in terms of designing mitigation measures to avoid negative impacts The selection of adequate storage collection and proper disposal could be steps to consider carefully

57 The Environmental and Social Screening Process

51 The objectives of sub-project screening is to determine which activities are likely to have negative environmental and social impacts

571 Subproject Screening Procedures

52 The sub-projects funded under this project are generally categorized as Category B or C and screening mechanisms would ensure that any identified Category A sub-projects are not funded under the project Due to the fact that most Category B sub-projects are small-scale which do not result in adverse negative environmental impacts this will require an ESMP which has clear due diligence environmental and social procedures (including the setting out of institutional responsibilities timing and budget) for sub-projects The ESMP should take into consideration the applicable requirements under the Bankrsquos ten safeguard policies

572 Environmental Sub-Project Screening Checklistsforms

53 The Operation Manual (OM) should contain for each type of sub-project a simple environmental screening checklist (Form 1)) which poses a series of questions designed to identify risks to the environment The goal of the checklist (also called a screening or environmental data sheet) is to identify which sub-projects require more environmental information in the form of a site-specific ESMP or which can proceed without any special mitigation measures that is falling under category C

Form 1 Environmental Screening Check-list

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

5

EXECUTIVE SUMMARY

This Report has been prepared to present the environmental requirements and guidelines for the Social Promotion and Protection Project (SPPP) that the Government of Lebanon is planning to initiate through the Ministry of Social Affairs (MOSA)

Project DescriptionThe project consists of three components (i) developing the role and capacity of Social Development Centers (SDCs) (ii) establishing and supporting an effective national program in MOSA to finance community developed and driven projects and (iii) continued roll-out and institutionalization of the National Poverty Targeting Program (NPTP)

This Environmental Social Assessment Framework (ESAF) is designed to ensure protection of the health and livelihood of beneficiaries and the environment The framework is intended to protect against both local impacts of individual subprojects and the cumulative impact of many similar subprojects in the same area

Many subprojects have little or no adverse impact However it is important to acknowledge possible unfavorable effects Experience shows that CDD projects need to establish simple social and environmental assessment procedures to avoid causing adverse harm to human health and the environment

The main elements of the Environmental Social Assessment Framework are (1) Tools These tools usually include guidance written in the local language and presented in a form easily understood by community facilitators (2)Implementation Arrangements A description of roles and responsibilities to ensure that the identification avoidance and mitigation of environmental and social risks should be built into sub-project preparation appraisal and supervision (3) Capacity Building Training must be provided to ensure that every person with a role in the safeguard implementation arrangements is able to fulfill their responsibilities (4) Supervision and Monitoring Arrangements should be in place to supervise both the adequacy and application of the safeguard management tools (5) Audit During preparation of the program it is useful to agree that an independent audit of the Safeguards Management Framework will be undertaken at mid-term to draw lessons and recommend improvements

The implementation of the SPPP falls under the responsibility of MOSA who would be in charge of coordinating the various activities through its Social Development Centers (SDC) with concerned local governments and NGOs A Project Coordination Team (PCT) will be established and would comprise experts with relevant experience in implementing similar projects and with proven capacity to handle all functions required in such a project Among its mandates the PCT will ensure that any sponsored subproject is environmentally sound and sustainableThe World Bank Operational Policy (OP 401) on Environmental Assessment (January 1999) defines the Bankrsquos environmental assessment requirements to ensure that funded projects are

6

environmentally sound and sustainable A screening process is undertaken for all funded projects to assess the magnitude and adversity of predicted environmental impacts and to determine the appropriate extent and type of EA Depending on the type location sensitivity and scale of the project as well as the nature and magnitude of environmental impacts projects are classified into one of three categories

(a)- Category A Projects that are likely to cause significant and possibly irremediable environmental impacts

(b)- Category B Projects that might cause lesser adverse impacts than those of Category A and the impacts are often remediable or mitigable

(c)- Category C Projects which could have minimal or no adverse environmental impacts

Subprojects funded by the SPPP are classified as Category B or Category C Sub-projects found to be category A as per World Bank environmental safeguards classification will not be funded by the project

Following this division sub-projects falling only under categories B will need Environmental and Social Management Plans (ESMPs) to be prepared and reviewed for clearance prior to providing final approval for the sub-project

This document describes the needed step and tools that need to be looked at in the design of the sub-project as well as the mitigation measures needed for implementation that takes into account all environmental and social considerations and thus mitigates for any negative impacts in this regard

7

1 INTRODUCTION

11 Background

This document constitutes an integral part of the Project Appraisal Document intended for a World Bank loan to the Government of Lebanon at a total value of USD 30 Million for the implementation of the Social Promotion and Protection Project (SPPP) It has been prepared to present the environmental requirements and guidelines for the SPPP that the Government of Lebanon is planning to initiate through the Ministry of Social Affairs (MOSA)

PROJECT DEVELOPMENT OBJECTIVES

A Project Development Objective

1 The development objective of SPPP is to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

Project Beneficiaries

2 The SPPP beneficiaries consist of the following three categories

(a) Poor and Vulnerable Households and Community Members The ultimate beneficiaries of the project include (a) vulnerable individuals and households (eg children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) who will have improved access to social services provided by SDCs (b) poor and vulnerable individuals who will receive assistance through income generating activities (IGAs) as well as others in the community who will find new employment or experience increased earnings stimulated by growth of IGAs and (c) the poor households who will be eligible to receive NPTP benefits

(b) MOSA The project will help strengthen MOSArsquos capacity to carry out its official mandate both at the central level and through the SDCs at the local levels In particular MOSA will be supported in managing the implementation of small projects using a community-based demand-driven and participatory approach so as to position itself as the main government actor for community development activities in the social sphere At the same time the continued implementation of the NPTP will help MOSA develop the skills needed for administering well-targeted and efficient social safety nets

(c) Civil Society Organizations (CSOs) CSOs will also benefit from the project as they will have an opportunity to improve their capacity to propose prepare and implement income-generating projects and social services at the community level

8

B Project Components

3 The SPPP will have the following four components (1) Social Development Centers (SDCs) (2) Community Social Development Program (CSD) (3) National Poverty Targeting Program (NPTP) and (4) Project Coordination Team (PCT) Component 1 which focuses on building the capacity of the SDCs is cross-cutting between Components 2 and 3 as the SDCs are the local implementing arms of MOSArsquos mandate Specifically both the CSD and NPTP programs rely on the SDCs for implementation

Component 1 Social Development Centers (SDCs) (US$952 million total cost of which US$908 million to be financed from the loan)

4 The objective of this component is to enhance the administrative and operational capacity of the SDCs to enable them to offer social services of improved quality and relevance This component will also include key cross-component functions such as monitoring and evaluation social accountability measures and communication outreach To achieve the above this component will consist of the following sub-components

(a) Equipping automating and electronically linking the SDCs to the central unit at MOSA The project will finance (i) necessary equipment and software to computerize systems and processes at the SDCs (eg creating databases) and to ensure proper processing of NPTP transactions (ii) the establishment of a computerized modular MIS with dedicated modules for the CSD and NPTP1 programs as well as for other core functions (eg procurement financial management) and accessible to both SDCs and the central MOSA unit (iii) internet connectivity between the SDCs and MOSA and (iv) small works and equipment to refurbish and rehabilitate the SDCs as needed

(b) Building and empowering the human resources of the SDCs The project will finance training of SDC staff including in (i) the use of new equipment and systems (ii) specific topics to support the implementation of the CSD and NPTP programs such as handling grievances writing proposals and applying case management and participatory approaches

(c) Community participation The project will finance capacity building and technical assistance for SDCs to (i) establish mechanisms at the SDC level to facilitate community consultation in the SDC catchment area in the form of ldquoLocal Consultative Platformsrdquo (LCP) and (ii) create inventories of local social service providers carry out social needs assessments and prioritization and establish referral systems to ensure that social services match community needs

(d) Monitoring and Evaluation Social Audits and Communication Outreach (see Section IV B for further details) The project will finance the development of a comprehensive MampE system relying primarily on the computerized MIS as well as training of MOSA staff and the project team to use it This will include assessing the performance of the present NPTP MampE system improving it as needed and

1 As an NPTP module is already in use any needed upgrading will be handled under the NPTP Component

9

carrying out short surveys on a regular basis (eg opinion polls) As part of the monitoring effort as well as to promote good governance this component will finance social audits Communication outreach campaigns for the NPTP and the CSD programs will also be supported

Component 2 Community Social Development Program (CSD) (US$1729 million total cost of which US$1232 million to be financed from the loan)

5 This component aims to establish a transparent accountable and efficient national CSD program that will finance community-based sub-projects through grants The CSD program is designed building on the experience of the World Bank-supported Community Development Project (2001-2008) MOSA experiences as well as lessons learnt from other CDD programs in Lebanon and around the world Grant sizes are limited to US$50000 equivalent implementation time for each sub-grant is one year and beneficiaries will be required to make contributions upfront Targeting will be done according to two criteria (a) geographic targeting to prioritize areas of greater poverty and deprivation (eg Akkar district) based on information from updated poverty estimates and studies carried out by various donors (eg the European Union) and (b) categorical targeting to prioritize vulnerable groups (eg the handicapped) based on MOSArsquos mandate The component will consist of the following two sub-components

(a) Establishment of a National Community Social Development Program in MOSA the project will finance technical assistance in the form of key experts (eg CSD program manager engineer social specialist income-generating specialist) who will manage a transparent process of calls for proposals screening and prioritization of proposals and monitoring and supervision of sub-grant implementation

(b) Funding community-driven sub-projects The project will provide grants to eligible applicants (primarily SDCs and CSO) whose projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

10

Component 3 National Poverty Targeting Program (NPTP) (US$17286 million total cost of which US$665 million to be financed from the loan)

6 This component aims to expand the coverage from approximately 100300 (expected in 2013 baseline of SPPP) to 238700 (in 2018) individual beneficiaries as well as to improve the efficiency of the NPTP To achieve this objective the project will provide technical support for the continued roll-out and institutionalization of the NPTP which was launched in 2011 under the Bank-financed Second Emergency Social Protection Implementation Support Project (ESPISP II) Presently NPTP benefits consist of waived school and hospitalization fees coverage of chronic disease medications free schoolbooks and discounts on electricity bills The cost of these benefits as well as that of the SDC social workers involved in administering the program are being borne and will continue to be borne by the Government2 To achieve its objective this component will consist of the following three sub-components

(a) Continued roll-out and institutionalization The project will finance technical assistance for (i) supporting the program management team (ii) refining the program application forms and Proxy-Mean Testing (PMT) questionnaire (iii) upgrading the MIS module for the NPTP and establishing an archiving system (iv) adopting measures to prevent and discourage fraud and corruption (v) refining the grievance and redress mechanism for improved efficiency and transparency

(b) Access to social safety nets The project will finance technical assistance for (i) assessing the performance of the reimbursement mechanism of the NPTP benefits and designing any improvements and (ii) designing and piloting a case management approach with NPTP beneficiary households

(c) Enabling evidence-based policy making for poverty reduction The project will finance (i) technical assistance to support the Inter-ministerial Committee for Social Policy (Social-IMC) and its Secretariat (ii) technical assistance to establish a Poverty Analysis Team whose role will be to assess the poverty and inequality situation in Lebanon using Household Budget Survey (HBS) data and (iii) the design and implementation of the next HBS (in 2017) which will be a large-sample survey representative at the governorate (mohafazat) level

Component 4 Project Coordination Team (PCT) (US$214 million out of which US$195 from the loan)

7 The project will finance a team who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components (see Section III and Annex IV of the Project Appraisal Document) reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively

2 The Council of Ministers allocated US$28 million in 2011 to finance the benefits and approximately US$4 million for the hiring of 350 social workers

11

contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management

12 IMPLEMENTATION

a Institutional and Implementation Arrangements

8 MOSA is the project implementing agency and it will oversee the implementation of all SPPP activities A Project Coordinator will head the PCT and also be responsible for the implementation of Component 1 assisted by a Project Officer while Components 2 and 3 will each be headed by a Program Manager These positions will be financed by project funds A combination of contracted and MOSA staff will be responsible for the implementation of component activities

9 Each component will be overseen by a MOSA committee that will report to the Minister In the case of Components 2 and 3 the committee will be an ldquoEmanating Project Committeerdquo3 which will check the legal aspect of all activities financed and implemented by the component (which is considered an ldquoemanating projectrdquo) and oversee the way the funds are being spent In the case of Component 1 the committee will be a SDC Committee consisting of the SDC Director and other MOSA staff4

10 The heads of the components and the MOSA Minister (as well as the Director General if the position is filled) will form the SPPP Steering Committee which will meet periodically to review implementation progress and ensure coherence with ministry policies At the national policy level the Social Inter-Ministerial Committee (Social-IMC) with MOSA acting as its Technical Secretariat will ensure coordination of the SPPP with other social policies5 Further details are provided in Annex 3 of the Loan Agreement

11 With respect to the institutional setup of the NPTP the program has been operating under a ldquodual managementrdquo by MOSA and the Presidency of the Council of Ministers (PCM)6 This was deemed the best option at the time of appraisal of the ESPISP II project which supported the

3Emanating Project Committees are established as a way to circumvent the cumbersome Lebanese bureaucracy while still providing appropriate oversight They generally comprise five or six members taken from high-ranking positions within the Ministry (eg Department Directors)4 Each SDC has its own Emanating Committee so it would not be possible to also have an Emanating Committee overseeing the component5The Social-IMC established on January 22 2007 by a decree signed by the Prime Minister and composed of the Ministers of Finance Social Affairs Health Education Labor Interior amp Municipal Affairs Economy amp Trade NSSF and the President of CDR is charged with (i) drafting a comprehensive integrated and coordinated social strategy (ii) coordinating government activities for the provisions of social services (iii) ensuring coordination of all studies surveys reports related to social affairs and ensuring availability of relevant social data and indicators (iv) overseeing the implementation of social safety net programs and (v) coordinating monitoring and evaluating development programs that are financed by local and international partners6 This dual management consists of a central management unit at the PCM and Management central unit in MOSA The former is responsible for (i) co-managing the central NPTP database (ii) validating data and cross-checking with national databases (iii) processing household data and generating scores and ranks according to the proxy-means testing (PMT) formula (iv) maintaining the PMT formula (v) analyzing national data and reporting findings to the Social Inter-Ministerial Committee (Social-IMC) (vi) monitoring the NPTP targeting and (vii) auditing data processing The central unit in MOSA (through its SDCs)is responsible for (i) co-managing the central NPTP database (ii) receiving household applications (iii) interfacing with applicants (iv) entering data (v) conducting household visits (vi) checking for data errors (vii) transmitting data to the central database of the NPTP CMU and (viii) managing the public relations campaign

12

creation of the NPTP7 The present institutional setup will be retained during the implementation of the SPPP though the GOL has started discussing the possibility of consolidating the NPTP under MOSA and institutionalizing it as an independent program with its own budgetary allocations

This document is intended to look at designing the Environmental and Social Assessment Framework (ESAF) for the sub-projects to be financed under Component 2 of the SPPP

b Purpose of the Environmental and Social Assessment Framework (ESAF)

12 The ESAF is designed to ensure protection of the health and livelihood of beneficiaries and the environment The framework is intended to protect against both local impacts of individual sub-projects and the cumulative impact of many similar subprojects in the same area

13 Although many sub-projects have little or no adverse impact it is important nonetheless to acknowledge the possible unfavorable effects Experience shows that CDD projects need to establish simple social and environmental assessment procedures to avoid causing adverse harm to human health and the environment

14 The main elements of the Environmental and Social Assessment Framework (ESAF)are described below

Tools These tools usually include guidance written in the local language and presented in a form easily understood by community facilitators as well as

(i) rules-based social and environmental criteria establishing basic dorsquos and donrsquots and indicating the permissions and clearances required for common activities and(ii) mitigation guidelines providing practical guidance for the avoidance or mitigation of potential environmental impacts and identifying issues for which more specific expert guidance should be sought

Implementation Arrangements A description of roles and responsibilities to ensure that the identification avoidance and mitigation of environmental and social risks should be built into sub-project preparation appraisal and supervision This normally includes roles at the levels of community facilitators local management and program-wide management These should also be reflected in any Operational Manual that is prepared This description should abide by the rules and regulations issued by the Ministry of Environment

Capacity Building Training must be provided to ensure that every person with a role in the safeguard implementation arrangements is able to fulfill their responsibilities It is important that training in environmental and social safeguards management is incorporated from the very start of the program before the preparation of sub-projects begins

Supervision and Monitoring Arrangements should be in place to supervise both the adequacy and application of the safeguard management tools In addition it is useful to keep track of environmental concerns in program areas so that more specific mitigation measures can be

7Other options were considered at the time and are detailed in the EPP of the ESPISP II

13

designed and opportunities for enhancements can be promoted Secondary information gathering is usually sufficient for this purpose

Audit During preparation of the program it is useful to agree that an independent audit of the ESAF will be undertaken at mid-term to draw lessons and recommend improvements

15 Experience has shown the value of involving environmental organizations particularly those with advocacy expertise in the design of the Environmental and Social Assessment Frameworks and subsequently in the associated capacity building supervision and monitoring This in fact was done through the consultation process as it will be documented in later sections of this document Access to environmental expertise can be facilitated during program implementation through the identification of local professionals with an environmental background who can form a resource pool to be mobilized locally as subprojects require

16 Social funds and CDD programs also provide important opportunities to promote pro-poor reforms in environmental policies particularly those associated with access to natural resources and their management The involvement of national and local environmental specialists can play a valuable role in advancing these agendas

17 A development project mitigation measures (Annex I) encompass all actions taken to eliminate offset or reduce potentially adverse environmental impacts to acceptable levels Such measures are typically associated with the latter stages of project planning although in practice they may occur at any stage throughout the project cycle Normally potential impacts are identified early during the initiation and scoping stages of EA for a project and measures to avoid or minimize impacts are incorporated into the alternatives being considered In this respect some of the most important measures to protect the environment or local communities become integral to the project design and are never reflected within a formal environmental and social management plan (ESMP) For example the environmental and social bases for choosing a preferred location for a project will not necessarily be evident within the ESMP

18 Environmental and Social Management Plans (ESMPs) outline the mitigation monitoring and institutional measures to be taken during sub-project implementation and operation to avoid or control adverse environmental impacts and the actions needed to implement these measures They provide a crucial link between alternative mitigation measures evaluated and described within the EA report and ensuring that such measures are implemented EA reports are essentially planning documents with no legal basis In many cases mitigation measures outlined in EAs are described in illustrative terms or have neither been committed to by the borrower nor reflected in the project design In this regard the ESMP is a basis for negotiation and reaching agreement with borrowers on a sub-projectrsquos key social and environmental performance standards

19 This report aims at providing guidance in identifying environmental assessment needs for the various sub-projects that are funded under Component 2 of the SPPP and might have the potential of inflicting environmental impacts that need to be addressedFunded sub-projects fall under two categories

14

(i) Social Development (a) improving access to specialized social services to satisfy the needs of vulnerable groups at risk including the disabled children youth women and the elderly (b) enhancing environmental protection initiatives such as reforestation and soil erosion control wells and spring protection and preservation of natural sites

(ii) Income Enhancement Capacity building activities to support (a) micro and small entrepreneurs and non-governmental organizations providing credit to target beneficiary groups and (b) women youth and disabled people in order to provide them with demand driven specialized skills to improve their income and enhance their business opportunities

2 POLICY LEGAL amp INSTITUTIONAL FRAMEWORK FOR THE ENVIRONMENT

21 Regulatory Framework for Environmental Impact Assessment

20 Presently the environmental framework of Lebanon is managed and supervised by the Ministry of Environment (MOE) that was created by law 216 of April 2nd 1993 to be the government institution responsible for the development of a national strategy for sustainable development This was strengthened through the Law 4442002 Framework Law for the Protection of the Environment and the CEA (Country Environmental Analysis) The MOE is undergoing several review procedures to up-date the countryrsquos environmental policies and regulations including the preparation of an Environmental Code issuance of an Environmental Impact Assessment (EIA) decree as well as norms and standards for environmental protection The Environmental codes as well as the EIA decree were prepared with the assistance of the World Bank under the Mediterranean Environmental Technical Assistance Program (METAP) Also the World Bank has financed through METAP an assessment of the EIA System in Lebanon (Annex II)

METAP has also supported the establishment of an Environmental Management System Unit (EMSU) dealing with EIA at the MOE The concept of EA as part of project planning in Lebanon is still new and has only recently gained some attention The Environmental Impact Assessment (EIA) decree that was prepared by the MOE will require that an EIA be prepared during the planning process of both public and private development projects in Lebanon

22 Existing Environmental Legislation

221 International Conventions

21 The Lebanese Government has ratified a large number of international conventions for Environmental Protection Among the most important ones are

The Barcelona Convention for the protection of the Mediterranean SEA International Convention on World Heritage Protection International Convention on Bio-diversity Protection United Nations Convention on Desertification Montreal Protocol for the protection of the Ozone layer

15

222 Existing Lebanese Legislations

22 A list of the most significant existing environmental legislation is given in Annex II The primary safeguards as they are likely to affect SPPP subprojects are summarized in the following sections

Natural LandscapeProtection of the natural landscape of Lebanon was first addressed under the Law of January 1949 Recently cutting of trees was severely restricted under Decree No142 of March 1993 and further protection was provided under Law No 550 dated July 1996 There are also a number of Laws and Decisions that were issued to protect sites of particularly valuable landscape by declaring them Natural Reserves

Soil Water and Air PollutionProtection against pollution was first addressed by Decree No 8735 of October 1974 that prohibited the digging of wells for the disposal of raw sewage banned infiltration from cesspools and the use of sewage for the irrigation of vegetables and some fruits Decision No 521 of July 1996 introduced measures to deal with the pollution of the air water and soil including national standards for drinking water bathing waters and wastewater quality Recently Decision No 81 dated March 2001completed and reviewed the previously issued standards

Water ResourcesGround and surface water resources have been protected since the introduction of Order No 144 dated June 1925 which covered the major springs that supply the countryrsquos potable and irrigation needs Zoning of water sources and recharging of catchment areas was introduced by Decree 10276 of October 1962 to cope with increasing demand for water In 1970 Decree 14438 established a limit on the depth and exploitation of unlicensed wells and boreholes 150 m and 100 m3d respectively

Archaeological and Historical SitesThe protection of archaeological and historic sites was first addressed in Law No 1666 of November 1933 Later legislation has been introduced to afford special protection to the Cultural Heritage World Heritage and Cultural Landscape Sites declared by UNESCO

Public StreetsLaw No 60 of September 1983 covers Work in public streets law No 98 of September 1989 and by Circular 695 issued by the Prime Ministerrsquos Office on March 1995

Decree 86332012 on EIA describes clearly the various measures that need to be considered in the preliminary Environmental Evaluation of any project Projects found to require further investigation will have to be subjected to an EIA whereby complete set of information is required to allow for the Ministry to suggest needed mitigation measures and issue accordingly needed permits The stipulations of the decree go in hand with most of the WB guidelines The decree describes the various categories of sub-projects that do

16

require EIA and what are the projects that might cause risks and hazards A copy of the decree will be attached as an Annex to this document

23 Permit Procedures

23 Depending on the type and size of the sub-project to be executed and according to the Lebanese legislation a number of approvals and permits might be required from various governmental agencies In view of their nature and scale the majority of the sub-projects that would be funded by the SPPP will only require the approval of the municipality and or the Ministry of Municipalities and Rural Affairs

3 POTENTIAL SIGNIFICANT ENVIRONMENTAL IMPACTS AND GOOD PRACTICE MITIGATION PROCEDURES

31 Positive Environnemental Impact

24 Most sub-projects financed by the SPPP that are well designed and properly implemented can have a positive impact on the environment The benefits of this type of sub-projects are often long term rather than short term and are not limited to the specific local community Examples of environmentally beneficial sub-projects that will be financed by the SPPP are subject to case by case assessment soil erosion protection protection of natural and cultural heritage sites

a Consultation and Public Disclosure

25 A simple approach is proposed for public consultation in the early stages of sub-project preparation and planning

The stakeholders should be made aware of the different elements and features of each sub-project and their main objectives and target groups Once an ESIA has been made the results of this study should be disclosed to all concerned primary stakeholders

The stakeholders should then be encouraged to share their concerns worries and any comments they have on the sub-project or its likely impacts This should include discussions on alternative and proposed mitigation measures that are to be accounted for in the sub-project design implementation and operation phases

The final step is to incorporate the stakeholder inputs into the sub-project plans in order to improve the sub-project design

26 The process of stakeholder involvement and consultation will continue during sub-project implementation as well in order to integrate any additional comments and worries that may arise from the construction and implementation phase

27 Consultation with the stakeholders may take different forms depending on the need and subject matter that is being communicated An informative method would be through the use of one-way communication techniques such as audio (radio) visual (television) printed (leaflets brochures pictures diagrams posters) or electronic media (internet and electronic mail) In this case the stakeholders will be merely informed with certain information and there shall be no opportunity for questions or comments In order to have interactive consultation with the

17

stakeholders two-way participatory techniques are required This may include one-to-one briefings small group and village meetings and the organization of workshops and forums

28 The technique used for the disclosure and dissemination of information and data should take into consideration stakeholder preferences and characteristics The disclosed information should be in a language that all stakeholders are familiar with and for those who are illiterate certain measures may need to be taken to ensure that they are fully aware of the contents of the disclosed documents Another important consideration is that ample time should be given to the stakeholders to review the disclosed information prior to the consultation process to allow them to thoroughly address the sub-projects various issues

29 The SPPP will also generate environmental benefits through a variety of other mechanisms among which are

(a)- Generation of environmental assessment guidelines that can be used by other organizations or ministries or could be adopted by the Ministry of Environment for more general use

(b)- Training of environmental specialists thus increasing the number of environmental professionals in the country

(c)- Improved environmental awareness in the local communities

b Future capacity building initiatives

30 These could be done through a structured training along two parallel lines (i) at the level of the implementing agencies when these are guided one by one through the process by the environmental specialist to help them look at the needed assessment and the mitigation measures if any (ii) at the level of the community by organizing awareness campaigns targeted to LCP and other prominent figures and other interested CSOs on environmental issues of relevance and how that affects the sub-projects implemented in their areas That creates a social accountability system that could be used to ensure that the sub-projects are implemented according to appropriate procedures

32 Negative Environmental Impacts

321 Overview of Negative Environmental Impacts

31 The SPPP will finance a considerable number of different types of subprojects An important percentage of the funding will be allocated for social development Though intended to improve environmental and social conditions these subprojects can have a variety of negative environmental impacts that might be encountered during the operation of the subprojects Environmental impacts arising from the operation of the different subprojects can be minimized by appropriate site selection good engineering design and appropriate construction techniques

4 IMPLEMENTATION ARRANGEMENTS

41 Environmental Guidelines

18

32 The implementation of the SPPP falls under the responsibility of MOSA who would be in charge of coordinating the various activities through its Social Development Centers (SDCs) with concerned local governments and NGOs A Project Coordination Team (PCT) will be established and would comprise experts with relevant experience in implementing similar projects and with proven capacity to handle all functions required in such a project Among its mandates the PCT will ensure that any sponsored subproject is environmentally sound and sustainable

33 The PCT shall ensure the following

Environmental considerations will be included as criteria for selecting activities to be supported by the project environmental assessment would become an integral part of the project cycle of any subproject

Environmental guidelines are followed and used throughout the project cycle

Environmental issues are introduced to beneficiaries through education and promotion of environmentally beneficial subprojects

34 The execution of the CSD will be undertaken by Civil Society Organizations (CSO) who would consist of qualified local authorities or national NGOs with strong community ties and proven execution capacity The SDC would assist local NGOs LCF and communities in identifying local needs preparing subprojects coordinating with concerned ministries and implementing the subprojects

42 Environmental Assessment (EA)

35 The World Bank Operational Policy (OP 401) on Environmental Assessment (January 1999) defines the Bankrsquos environmental assessment requirements to ensure that funded sub-projects are environmentally sound and sustainable A screening process is undertaken for all funded sub-projects to assess the magnitude and adversity of predicted environmental impacts and to determine the appropriate extent and type of EA Depending on the type location sensitivity and scale of the project as well as the nature and magnitude of environmental impacts sub-projects are classified into one of three categories

(a)- Category A Sub-Projects that are likely to cause significant and possibly irremediable environmental impacts

(b)- Category B Sub-Projects that might cause lesser adverse impacts than those of Category A and the impacts are often remediable or could be mitigated for

(c)- Category C Sub-Projects which could have minimal or no adverse environmental impacts

19

36 The SPPP will only fund sub-projects that can be classified as either Category B or Category C only For instance all income enhancement sub-projects will be classified as Category C while most social sub-projects will be Category B Sub-projects that are likely to cause substantial negative impacts and are expected to fall in Category A will not be approved for funding

37 This document will provide guidance with respect to the preparation of environmental assessment for the various funded subprojects These guidelines are based on the World Bank Operational Policies (OP 401) the Environmental Assessment Source book (1991) and its updates in addition to the Decree 86332012 on EA issued by the GOL

5 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

51 Objectives and Structure of the ESMP

38 The objectives of the ESMP are to mitigate the adverse environmental impacts identified in the SPPP The ESMP will consist of three kinds of activities

o Implementation of mitigation measures o Strengthening the capacities of PCT SDCs and local NGOs o Monitoring and evaluation of mitigation measures identified during subproject

formulation or within the environmental assessment report

52 Implementation of Mitigation Measures

39 Mitigation measures identified (Table 1) are for typical sub-projects and MOSAPCT will ensure that such measures are adhered to during the overall implementation of the SPPP

Table 1 Potential Environmental Impacts and Proposed Mitigation Measures for Different Subprojects

Project Component

Potential Impacts Mitigation Measures Responsibility

Roads rehabilitation

Clogging of natural drainage channelsEncroachment on private property

Dumping of construction wastes and accidental spills of machine fuels etcRisk of damage to unknown archaeological sites

Maintain ditches

Detailed property boundary surveys and flagging in fieldProper disposal of construction wastes

Use ldquochance findrdquo procedures and coordinate with appropriate

Contractor

ContractorIA

Contractor

IAsArcheology department

20

government agency

Rehabilitation of schools

Rehabilitation of health clinics

Irrigation and drainage

Improper disposal of wastes

Water quality degradation in ponds and reservoirsClogging of canals from weedssedimentsInefficient water flow because of heavy sedimentation

Degradation of water systems receiving irrigation waters by nutrients agrochemical and salts

Proper disposal of solid wastesPriority given to rehabilitation of toiletsInstallation of sanitation (cesspools)

Containerize infectious wastesPublic health awareness

Monitoring of water qualityOperation amp maintenance planProper design of canals and provision of access for weed and sediments removal

Control of agrochemical use

IAsMunicipality

IAscommunity

IAscommunity

Ministry of Health

Ministry of Energy and Water

IAs community

ContractorIAs

Ministry of Agriculturecommunity

53 Training Program and Capacity Building

40 The MOSA lacks the capacities and the expertise to work in the field of environmental monitoring and protection Moreover it is expected that the IAs mostly CSOs and SDCs do not have the needed resources to undertake the requirements needed in terms of EAs and designing mitigation measures This would require a detailed capacity building program that targets all levels of the decision making process in the project The central team at the MOSA and the PCT need to be oriented to the general approach to environmental safeguards importance use and how that could affect the selection implementation and monitoring of Sub-projects SDFCs and IAs should be trained on

21

the technical aspects of detection and mitigation and how these could be imbedded within the process of project identification to formulation to implementation These safeguards will have to be an integral part of any sub-project proposal and consequently any detailed action plan for any specific sub-project Environmental expertise within the implementing and executing bodies will be strengthened Training programs will designed and implemented with the assistance of a local or international expert and will target levels as stated in the Table 2 page 20

41 PCT and IAs At the initiation of the CSD and prior to bidding and selection of IAs a workshop will be provided and will include an environmental session to raise environmental awareness and to clarify the specific environmental requirements related to design and implementation of the SPPP

42 Another training workshop will be provided to the PCT and selected IAs and will cover the following to IAs

EIA techniques Screening sub-projects for environmental review Use of practical formschecklists Best environmental practices in design and implementation of projects Effective implementation of mitigation measures Project supervision Monitoring and evaluation

43 Local NGOs and Contractors IAs will be required to provide workshops for local NGOs and contractors focusing on public awareness case studies of environmental issues experienced in similar projects use of environmental guidelines and implementation of mitigation measures (Table 2 Annex III)

22

Table 2 Training and Capacity Building Program for Implementing the ESAFTraining

Capacity BuildingParticipating Stakeholders

Skills acquired Scheduling Cost Source

ManagementInstitutional

1year

SPPP manager MOSA central unit Head of concerned

departments at MOSA PCT

Decision making and delegation Work procedures Environmental awareness National guidelines WB guidelines Classification and mitigation

Prior to sub-project preparation Planning phase Refresher every 3 months as we

go along the project

Undertaken by the Environmental

SpecialistMiscellaneous

7500 USD

WBMOSA

Institutional at Intermediate levels

2 training sessions of 2 days year

(for SDC and IA X5 regions)

PCT Emanating committee SDC managers IAs

Environmental and social policies

Laws and regulations GOL and WB safeguards Evaluation and selection

During sub-project preparation Planning phase Sub-project evaluation

Undertaken by the Environmental

SpecialistMiscellaneous

30000 USD

WB MOSA

Implementation1 day session X2 year X 5 regions

IAs SDC staff Beneficiaries Municipalities

Environment and social tools Screening amp monitoring

methods Sustainability of the process Practical mitigation and

safeguards

During sub-project preparation Mobilization Implementation

Undertaken by the Environmental

SpecialistMiscellaneous

50000 USD

WB MOSA

Monitoring Evaluation and

Reporting1 dayX2 year X5

regions

IAs SDC staff Beneficiaries

Municipalities

Environmental and social monitoring and compliance

Progress report preparation Monitoring and Evaluation

During sub-project preparation MobilizationImplementation

Environmental Specialist + consultant

50000 USD

WB MOSA

Total 137500 USD (includes in kind contribution from MOSA)

23

54 Environmental Monitoring

44 Environmental Monitoring will be the responsibility of the ES PCT and MOSA Central Unit with the supervision of the LCP and will include compliance monitoring during implementation and also monitoring of significant impacts during the operation of the subproject

Table 3 Typical Examples of Monitoring Plan for the Operation of Different Subprojects

Sub-project Monitoring Indicators Responsibility FrequencyRoads rehabilitation

Operating drainage channels

NGOs in close coordination with local community

Semi-annual assessment

Improvements to Water Supply and Sanitation Facilities

Irrigation and drainage

Distribution network without leaksNo leakage or overflows of manholes or drainsWater Quality Monitoring

Irrigation network without leaksDrainage channels clean and properly maintainedWater quality parameters (pH COD BOD SS)

NGOs in close coordination with local community

Ministry of Health and Ministry of Energy and Water

NGOs in close coordination with local community

Testing by Ministry of Health and Ministry of Energy and Water

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Rehabilitation of schools

Rehabilitation of health clinics

Toilet facilities clean and functioning properlyDrinking water faucets clean and safe from contamination

NGOs in close coordination with local community and appropriate municipality

Ministry of Health in close coordination with local community

Semi-annual assessment

Semi-annual assessment

23

24

45 The Environmental Specialist (ES) of the PCT will also conduct periodic monitoring by visiting the sites of the various sub-projects at least twice during the implementation period of the sub-project

46 Monitoring indicators shall be developed for both the mobilization and the operation phase of the subprojects Monitoring of activities will have to ensure that mitigation measures of operations impacts are being implemented properly while the monitoring of operation is to ensure that no unforeseen negative impacts are arising

55 Sub-project Cycle

47 Component 2 of the SPPP is the Community Social Development Program (CSD) which will be financing community-based sub-projects through grants The Program will have two windows one for social services whereas the other is for Income Generation Activities (IGA) support with the review and approval mechanisms in large part being the same for both windows While Component 3 focuses on Poverty Targeting thus the services provided will have no impact on the environment component 1 will focus on the provision of technology and training to SDCs

48 Applicants will be invited to use standard forms (available on the MOSA website and upon request from SDCs) to submit proposals to the relevant SDC in cases where the applicant is the SDC itself the application will be submitted directly to the CSD program team in Beirut

49 SDCs will immediately check all proposals for completeness and give a receipt to the applicant with a proposal number proposals found to be incomplete will be rejected with an explanation All complete proposals will be presented for discussion to the relevant Local Community Platform (LCP) or equivalent consultative body to obtain feedback on among other things the actual need (in case of social services) or likely market value (in the case of IGA) of the proposed activity the reputation of the applicant the likely sustainability of the proposed activity the preliminary classification of the project within environmental categories (the final classification will be pending on the decision of the environmental specialist within the PCT) any problematic aspect (conflict of interest etc) and the overall compliance of the proposal with the purposes of the program This feedback is not binding but will be taken into consideration when deciding whether or not to fund the proposal The CSD program team will carry out a detailed desk review of all complete proposals to assess their technical quality as well as the budget and time line suggested for the sub-project The environmental specialist member of the Project Coordinating Team (PCT) will review the proposal and prepare all needed documentation based on his classification of the sub-project

56 Screening of Sub-Projects

50 Each sub-project to be implemented by an IA will be subjected to an environmental screening Using the screening form (Form 1) environmental and social checklists for the proposed sub-projects will be screened by the environmental specialist to identify any potential adverse impacts

25

From an environmental standpoint the screening form may identify impacts form sub-projects the issue of solid waste disposal at the site of a sub-project may come out as a point to look at in terms of designing mitigation measures to avoid negative impacts The selection of adequate storage collection and proper disposal could be steps to consider carefully

57 The Environmental and Social Screening Process

51 The objectives of sub-project screening is to determine which activities are likely to have negative environmental and social impacts

571 Subproject Screening Procedures

52 The sub-projects funded under this project are generally categorized as Category B or C and screening mechanisms would ensure that any identified Category A sub-projects are not funded under the project Due to the fact that most Category B sub-projects are small-scale which do not result in adverse negative environmental impacts this will require an ESMP which has clear due diligence environmental and social procedures (including the setting out of institutional responsibilities timing and budget) for sub-projects The ESMP should take into consideration the applicable requirements under the Bankrsquos ten safeguard policies

572 Environmental Sub-Project Screening Checklistsforms

53 The Operation Manual (OM) should contain for each type of sub-project a simple environmental screening checklist (Form 1)) which poses a series of questions designed to identify risks to the environment The goal of the checklist (also called a screening or environmental data sheet) is to identify which sub-projects require more environmental information in the form of a site-specific ESMP or which can proceed without any special mitigation measures that is falling under category C

Form 1 Environmental Screening Check-list

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

6

environmentally sound and sustainable A screening process is undertaken for all funded projects to assess the magnitude and adversity of predicted environmental impacts and to determine the appropriate extent and type of EA Depending on the type location sensitivity and scale of the project as well as the nature and magnitude of environmental impacts projects are classified into one of three categories

(a)- Category A Projects that are likely to cause significant and possibly irremediable environmental impacts

(b)- Category B Projects that might cause lesser adverse impacts than those of Category A and the impacts are often remediable or mitigable

(c)- Category C Projects which could have minimal or no adverse environmental impacts

Subprojects funded by the SPPP are classified as Category B or Category C Sub-projects found to be category A as per World Bank environmental safeguards classification will not be funded by the project

Following this division sub-projects falling only under categories B will need Environmental and Social Management Plans (ESMPs) to be prepared and reviewed for clearance prior to providing final approval for the sub-project

This document describes the needed step and tools that need to be looked at in the design of the sub-project as well as the mitigation measures needed for implementation that takes into account all environmental and social considerations and thus mitigates for any negative impacts in this regard

7

1 INTRODUCTION

11 Background

This document constitutes an integral part of the Project Appraisal Document intended for a World Bank loan to the Government of Lebanon at a total value of USD 30 Million for the implementation of the Social Promotion and Protection Project (SPPP) It has been prepared to present the environmental requirements and guidelines for the SPPP that the Government of Lebanon is planning to initiate through the Ministry of Social Affairs (MOSA)

PROJECT DEVELOPMENT OBJECTIVES

A Project Development Objective

1 The development objective of SPPP is to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

Project Beneficiaries

2 The SPPP beneficiaries consist of the following three categories

(a) Poor and Vulnerable Households and Community Members The ultimate beneficiaries of the project include (a) vulnerable individuals and households (eg children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) who will have improved access to social services provided by SDCs (b) poor and vulnerable individuals who will receive assistance through income generating activities (IGAs) as well as others in the community who will find new employment or experience increased earnings stimulated by growth of IGAs and (c) the poor households who will be eligible to receive NPTP benefits

(b) MOSA The project will help strengthen MOSArsquos capacity to carry out its official mandate both at the central level and through the SDCs at the local levels In particular MOSA will be supported in managing the implementation of small projects using a community-based demand-driven and participatory approach so as to position itself as the main government actor for community development activities in the social sphere At the same time the continued implementation of the NPTP will help MOSA develop the skills needed for administering well-targeted and efficient social safety nets

(c) Civil Society Organizations (CSOs) CSOs will also benefit from the project as they will have an opportunity to improve their capacity to propose prepare and implement income-generating projects and social services at the community level

8

B Project Components

3 The SPPP will have the following four components (1) Social Development Centers (SDCs) (2) Community Social Development Program (CSD) (3) National Poverty Targeting Program (NPTP) and (4) Project Coordination Team (PCT) Component 1 which focuses on building the capacity of the SDCs is cross-cutting between Components 2 and 3 as the SDCs are the local implementing arms of MOSArsquos mandate Specifically both the CSD and NPTP programs rely on the SDCs for implementation

Component 1 Social Development Centers (SDCs) (US$952 million total cost of which US$908 million to be financed from the loan)

4 The objective of this component is to enhance the administrative and operational capacity of the SDCs to enable them to offer social services of improved quality and relevance This component will also include key cross-component functions such as monitoring and evaluation social accountability measures and communication outreach To achieve the above this component will consist of the following sub-components

(a) Equipping automating and electronically linking the SDCs to the central unit at MOSA The project will finance (i) necessary equipment and software to computerize systems and processes at the SDCs (eg creating databases) and to ensure proper processing of NPTP transactions (ii) the establishment of a computerized modular MIS with dedicated modules for the CSD and NPTP1 programs as well as for other core functions (eg procurement financial management) and accessible to both SDCs and the central MOSA unit (iii) internet connectivity between the SDCs and MOSA and (iv) small works and equipment to refurbish and rehabilitate the SDCs as needed

(b) Building and empowering the human resources of the SDCs The project will finance training of SDC staff including in (i) the use of new equipment and systems (ii) specific topics to support the implementation of the CSD and NPTP programs such as handling grievances writing proposals and applying case management and participatory approaches

(c) Community participation The project will finance capacity building and technical assistance for SDCs to (i) establish mechanisms at the SDC level to facilitate community consultation in the SDC catchment area in the form of ldquoLocal Consultative Platformsrdquo (LCP) and (ii) create inventories of local social service providers carry out social needs assessments and prioritization and establish referral systems to ensure that social services match community needs

(d) Monitoring and Evaluation Social Audits and Communication Outreach (see Section IV B for further details) The project will finance the development of a comprehensive MampE system relying primarily on the computerized MIS as well as training of MOSA staff and the project team to use it This will include assessing the performance of the present NPTP MampE system improving it as needed and

1 As an NPTP module is already in use any needed upgrading will be handled under the NPTP Component

9

carrying out short surveys on a regular basis (eg opinion polls) As part of the monitoring effort as well as to promote good governance this component will finance social audits Communication outreach campaigns for the NPTP and the CSD programs will also be supported

Component 2 Community Social Development Program (CSD) (US$1729 million total cost of which US$1232 million to be financed from the loan)

5 This component aims to establish a transparent accountable and efficient national CSD program that will finance community-based sub-projects through grants The CSD program is designed building on the experience of the World Bank-supported Community Development Project (2001-2008) MOSA experiences as well as lessons learnt from other CDD programs in Lebanon and around the world Grant sizes are limited to US$50000 equivalent implementation time for each sub-grant is one year and beneficiaries will be required to make contributions upfront Targeting will be done according to two criteria (a) geographic targeting to prioritize areas of greater poverty and deprivation (eg Akkar district) based on information from updated poverty estimates and studies carried out by various donors (eg the European Union) and (b) categorical targeting to prioritize vulnerable groups (eg the handicapped) based on MOSArsquos mandate The component will consist of the following two sub-components

(a) Establishment of a National Community Social Development Program in MOSA the project will finance technical assistance in the form of key experts (eg CSD program manager engineer social specialist income-generating specialist) who will manage a transparent process of calls for proposals screening and prioritization of proposals and monitoring and supervision of sub-grant implementation

(b) Funding community-driven sub-projects The project will provide grants to eligible applicants (primarily SDCs and CSO) whose projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

10

Component 3 National Poverty Targeting Program (NPTP) (US$17286 million total cost of which US$665 million to be financed from the loan)

6 This component aims to expand the coverage from approximately 100300 (expected in 2013 baseline of SPPP) to 238700 (in 2018) individual beneficiaries as well as to improve the efficiency of the NPTP To achieve this objective the project will provide technical support for the continued roll-out and institutionalization of the NPTP which was launched in 2011 under the Bank-financed Second Emergency Social Protection Implementation Support Project (ESPISP II) Presently NPTP benefits consist of waived school and hospitalization fees coverage of chronic disease medications free schoolbooks and discounts on electricity bills The cost of these benefits as well as that of the SDC social workers involved in administering the program are being borne and will continue to be borne by the Government2 To achieve its objective this component will consist of the following three sub-components

(a) Continued roll-out and institutionalization The project will finance technical assistance for (i) supporting the program management team (ii) refining the program application forms and Proxy-Mean Testing (PMT) questionnaire (iii) upgrading the MIS module for the NPTP and establishing an archiving system (iv) adopting measures to prevent and discourage fraud and corruption (v) refining the grievance and redress mechanism for improved efficiency and transparency

(b) Access to social safety nets The project will finance technical assistance for (i) assessing the performance of the reimbursement mechanism of the NPTP benefits and designing any improvements and (ii) designing and piloting a case management approach with NPTP beneficiary households

(c) Enabling evidence-based policy making for poverty reduction The project will finance (i) technical assistance to support the Inter-ministerial Committee for Social Policy (Social-IMC) and its Secretariat (ii) technical assistance to establish a Poverty Analysis Team whose role will be to assess the poverty and inequality situation in Lebanon using Household Budget Survey (HBS) data and (iii) the design and implementation of the next HBS (in 2017) which will be a large-sample survey representative at the governorate (mohafazat) level

Component 4 Project Coordination Team (PCT) (US$214 million out of which US$195 from the loan)

7 The project will finance a team who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components (see Section III and Annex IV of the Project Appraisal Document) reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively

2 The Council of Ministers allocated US$28 million in 2011 to finance the benefits and approximately US$4 million for the hiring of 350 social workers

11

contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management

12 IMPLEMENTATION

a Institutional and Implementation Arrangements

8 MOSA is the project implementing agency and it will oversee the implementation of all SPPP activities A Project Coordinator will head the PCT and also be responsible for the implementation of Component 1 assisted by a Project Officer while Components 2 and 3 will each be headed by a Program Manager These positions will be financed by project funds A combination of contracted and MOSA staff will be responsible for the implementation of component activities

9 Each component will be overseen by a MOSA committee that will report to the Minister In the case of Components 2 and 3 the committee will be an ldquoEmanating Project Committeerdquo3 which will check the legal aspect of all activities financed and implemented by the component (which is considered an ldquoemanating projectrdquo) and oversee the way the funds are being spent In the case of Component 1 the committee will be a SDC Committee consisting of the SDC Director and other MOSA staff4

10 The heads of the components and the MOSA Minister (as well as the Director General if the position is filled) will form the SPPP Steering Committee which will meet periodically to review implementation progress and ensure coherence with ministry policies At the national policy level the Social Inter-Ministerial Committee (Social-IMC) with MOSA acting as its Technical Secretariat will ensure coordination of the SPPP with other social policies5 Further details are provided in Annex 3 of the Loan Agreement

11 With respect to the institutional setup of the NPTP the program has been operating under a ldquodual managementrdquo by MOSA and the Presidency of the Council of Ministers (PCM)6 This was deemed the best option at the time of appraisal of the ESPISP II project which supported the

3Emanating Project Committees are established as a way to circumvent the cumbersome Lebanese bureaucracy while still providing appropriate oversight They generally comprise five or six members taken from high-ranking positions within the Ministry (eg Department Directors)4 Each SDC has its own Emanating Committee so it would not be possible to also have an Emanating Committee overseeing the component5The Social-IMC established on January 22 2007 by a decree signed by the Prime Minister and composed of the Ministers of Finance Social Affairs Health Education Labor Interior amp Municipal Affairs Economy amp Trade NSSF and the President of CDR is charged with (i) drafting a comprehensive integrated and coordinated social strategy (ii) coordinating government activities for the provisions of social services (iii) ensuring coordination of all studies surveys reports related to social affairs and ensuring availability of relevant social data and indicators (iv) overseeing the implementation of social safety net programs and (v) coordinating monitoring and evaluating development programs that are financed by local and international partners6 This dual management consists of a central management unit at the PCM and Management central unit in MOSA The former is responsible for (i) co-managing the central NPTP database (ii) validating data and cross-checking with national databases (iii) processing household data and generating scores and ranks according to the proxy-means testing (PMT) formula (iv) maintaining the PMT formula (v) analyzing national data and reporting findings to the Social Inter-Ministerial Committee (Social-IMC) (vi) monitoring the NPTP targeting and (vii) auditing data processing The central unit in MOSA (through its SDCs)is responsible for (i) co-managing the central NPTP database (ii) receiving household applications (iii) interfacing with applicants (iv) entering data (v) conducting household visits (vi) checking for data errors (vii) transmitting data to the central database of the NPTP CMU and (viii) managing the public relations campaign

12

creation of the NPTP7 The present institutional setup will be retained during the implementation of the SPPP though the GOL has started discussing the possibility of consolidating the NPTP under MOSA and institutionalizing it as an independent program with its own budgetary allocations

This document is intended to look at designing the Environmental and Social Assessment Framework (ESAF) for the sub-projects to be financed under Component 2 of the SPPP

b Purpose of the Environmental and Social Assessment Framework (ESAF)

12 The ESAF is designed to ensure protection of the health and livelihood of beneficiaries and the environment The framework is intended to protect against both local impacts of individual sub-projects and the cumulative impact of many similar subprojects in the same area

13 Although many sub-projects have little or no adverse impact it is important nonetheless to acknowledge the possible unfavorable effects Experience shows that CDD projects need to establish simple social and environmental assessment procedures to avoid causing adverse harm to human health and the environment

14 The main elements of the Environmental and Social Assessment Framework (ESAF)are described below

Tools These tools usually include guidance written in the local language and presented in a form easily understood by community facilitators as well as

(i) rules-based social and environmental criteria establishing basic dorsquos and donrsquots and indicating the permissions and clearances required for common activities and(ii) mitigation guidelines providing practical guidance for the avoidance or mitigation of potential environmental impacts and identifying issues for which more specific expert guidance should be sought

Implementation Arrangements A description of roles and responsibilities to ensure that the identification avoidance and mitigation of environmental and social risks should be built into sub-project preparation appraisal and supervision This normally includes roles at the levels of community facilitators local management and program-wide management These should also be reflected in any Operational Manual that is prepared This description should abide by the rules and regulations issued by the Ministry of Environment

Capacity Building Training must be provided to ensure that every person with a role in the safeguard implementation arrangements is able to fulfill their responsibilities It is important that training in environmental and social safeguards management is incorporated from the very start of the program before the preparation of sub-projects begins

Supervision and Monitoring Arrangements should be in place to supervise both the adequacy and application of the safeguard management tools In addition it is useful to keep track of environmental concerns in program areas so that more specific mitigation measures can be

7Other options were considered at the time and are detailed in the EPP of the ESPISP II

13

designed and opportunities for enhancements can be promoted Secondary information gathering is usually sufficient for this purpose

Audit During preparation of the program it is useful to agree that an independent audit of the ESAF will be undertaken at mid-term to draw lessons and recommend improvements

15 Experience has shown the value of involving environmental organizations particularly those with advocacy expertise in the design of the Environmental and Social Assessment Frameworks and subsequently in the associated capacity building supervision and monitoring This in fact was done through the consultation process as it will be documented in later sections of this document Access to environmental expertise can be facilitated during program implementation through the identification of local professionals with an environmental background who can form a resource pool to be mobilized locally as subprojects require

16 Social funds and CDD programs also provide important opportunities to promote pro-poor reforms in environmental policies particularly those associated with access to natural resources and their management The involvement of national and local environmental specialists can play a valuable role in advancing these agendas

17 A development project mitigation measures (Annex I) encompass all actions taken to eliminate offset or reduce potentially adverse environmental impacts to acceptable levels Such measures are typically associated with the latter stages of project planning although in practice they may occur at any stage throughout the project cycle Normally potential impacts are identified early during the initiation and scoping stages of EA for a project and measures to avoid or minimize impacts are incorporated into the alternatives being considered In this respect some of the most important measures to protect the environment or local communities become integral to the project design and are never reflected within a formal environmental and social management plan (ESMP) For example the environmental and social bases for choosing a preferred location for a project will not necessarily be evident within the ESMP

18 Environmental and Social Management Plans (ESMPs) outline the mitigation monitoring and institutional measures to be taken during sub-project implementation and operation to avoid or control adverse environmental impacts and the actions needed to implement these measures They provide a crucial link between alternative mitigation measures evaluated and described within the EA report and ensuring that such measures are implemented EA reports are essentially planning documents with no legal basis In many cases mitigation measures outlined in EAs are described in illustrative terms or have neither been committed to by the borrower nor reflected in the project design In this regard the ESMP is a basis for negotiation and reaching agreement with borrowers on a sub-projectrsquos key social and environmental performance standards

19 This report aims at providing guidance in identifying environmental assessment needs for the various sub-projects that are funded under Component 2 of the SPPP and might have the potential of inflicting environmental impacts that need to be addressedFunded sub-projects fall under two categories

14

(i) Social Development (a) improving access to specialized social services to satisfy the needs of vulnerable groups at risk including the disabled children youth women and the elderly (b) enhancing environmental protection initiatives such as reforestation and soil erosion control wells and spring protection and preservation of natural sites

(ii) Income Enhancement Capacity building activities to support (a) micro and small entrepreneurs and non-governmental organizations providing credit to target beneficiary groups and (b) women youth and disabled people in order to provide them with demand driven specialized skills to improve their income and enhance their business opportunities

2 POLICY LEGAL amp INSTITUTIONAL FRAMEWORK FOR THE ENVIRONMENT

21 Regulatory Framework for Environmental Impact Assessment

20 Presently the environmental framework of Lebanon is managed and supervised by the Ministry of Environment (MOE) that was created by law 216 of April 2nd 1993 to be the government institution responsible for the development of a national strategy for sustainable development This was strengthened through the Law 4442002 Framework Law for the Protection of the Environment and the CEA (Country Environmental Analysis) The MOE is undergoing several review procedures to up-date the countryrsquos environmental policies and regulations including the preparation of an Environmental Code issuance of an Environmental Impact Assessment (EIA) decree as well as norms and standards for environmental protection The Environmental codes as well as the EIA decree were prepared with the assistance of the World Bank under the Mediterranean Environmental Technical Assistance Program (METAP) Also the World Bank has financed through METAP an assessment of the EIA System in Lebanon (Annex II)

METAP has also supported the establishment of an Environmental Management System Unit (EMSU) dealing with EIA at the MOE The concept of EA as part of project planning in Lebanon is still new and has only recently gained some attention The Environmental Impact Assessment (EIA) decree that was prepared by the MOE will require that an EIA be prepared during the planning process of both public and private development projects in Lebanon

22 Existing Environmental Legislation

221 International Conventions

21 The Lebanese Government has ratified a large number of international conventions for Environmental Protection Among the most important ones are

The Barcelona Convention for the protection of the Mediterranean SEA International Convention on World Heritage Protection International Convention on Bio-diversity Protection United Nations Convention on Desertification Montreal Protocol for the protection of the Ozone layer

15

222 Existing Lebanese Legislations

22 A list of the most significant existing environmental legislation is given in Annex II The primary safeguards as they are likely to affect SPPP subprojects are summarized in the following sections

Natural LandscapeProtection of the natural landscape of Lebanon was first addressed under the Law of January 1949 Recently cutting of trees was severely restricted under Decree No142 of March 1993 and further protection was provided under Law No 550 dated July 1996 There are also a number of Laws and Decisions that were issued to protect sites of particularly valuable landscape by declaring them Natural Reserves

Soil Water and Air PollutionProtection against pollution was first addressed by Decree No 8735 of October 1974 that prohibited the digging of wells for the disposal of raw sewage banned infiltration from cesspools and the use of sewage for the irrigation of vegetables and some fruits Decision No 521 of July 1996 introduced measures to deal with the pollution of the air water and soil including national standards for drinking water bathing waters and wastewater quality Recently Decision No 81 dated March 2001completed and reviewed the previously issued standards

Water ResourcesGround and surface water resources have been protected since the introduction of Order No 144 dated June 1925 which covered the major springs that supply the countryrsquos potable and irrigation needs Zoning of water sources and recharging of catchment areas was introduced by Decree 10276 of October 1962 to cope with increasing demand for water In 1970 Decree 14438 established a limit on the depth and exploitation of unlicensed wells and boreholes 150 m and 100 m3d respectively

Archaeological and Historical SitesThe protection of archaeological and historic sites was first addressed in Law No 1666 of November 1933 Later legislation has been introduced to afford special protection to the Cultural Heritage World Heritage and Cultural Landscape Sites declared by UNESCO

Public StreetsLaw No 60 of September 1983 covers Work in public streets law No 98 of September 1989 and by Circular 695 issued by the Prime Ministerrsquos Office on March 1995

Decree 86332012 on EIA describes clearly the various measures that need to be considered in the preliminary Environmental Evaluation of any project Projects found to require further investigation will have to be subjected to an EIA whereby complete set of information is required to allow for the Ministry to suggest needed mitigation measures and issue accordingly needed permits The stipulations of the decree go in hand with most of the WB guidelines The decree describes the various categories of sub-projects that do

16

require EIA and what are the projects that might cause risks and hazards A copy of the decree will be attached as an Annex to this document

23 Permit Procedures

23 Depending on the type and size of the sub-project to be executed and according to the Lebanese legislation a number of approvals and permits might be required from various governmental agencies In view of their nature and scale the majority of the sub-projects that would be funded by the SPPP will only require the approval of the municipality and or the Ministry of Municipalities and Rural Affairs

3 POTENTIAL SIGNIFICANT ENVIRONMENTAL IMPACTS AND GOOD PRACTICE MITIGATION PROCEDURES

31 Positive Environnemental Impact

24 Most sub-projects financed by the SPPP that are well designed and properly implemented can have a positive impact on the environment The benefits of this type of sub-projects are often long term rather than short term and are not limited to the specific local community Examples of environmentally beneficial sub-projects that will be financed by the SPPP are subject to case by case assessment soil erosion protection protection of natural and cultural heritage sites

a Consultation and Public Disclosure

25 A simple approach is proposed for public consultation in the early stages of sub-project preparation and planning

The stakeholders should be made aware of the different elements and features of each sub-project and their main objectives and target groups Once an ESIA has been made the results of this study should be disclosed to all concerned primary stakeholders

The stakeholders should then be encouraged to share their concerns worries and any comments they have on the sub-project or its likely impacts This should include discussions on alternative and proposed mitigation measures that are to be accounted for in the sub-project design implementation and operation phases

The final step is to incorporate the stakeholder inputs into the sub-project plans in order to improve the sub-project design

26 The process of stakeholder involvement and consultation will continue during sub-project implementation as well in order to integrate any additional comments and worries that may arise from the construction and implementation phase

27 Consultation with the stakeholders may take different forms depending on the need and subject matter that is being communicated An informative method would be through the use of one-way communication techniques such as audio (radio) visual (television) printed (leaflets brochures pictures diagrams posters) or electronic media (internet and electronic mail) In this case the stakeholders will be merely informed with certain information and there shall be no opportunity for questions or comments In order to have interactive consultation with the

17

stakeholders two-way participatory techniques are required This may include one-to-one briefings small group and village meetings and the organization of workshops and forums

28 The technique used for the disclosure and dissemination of information and data should take into consideration stakeholder preferences and characteristics The disclosed information should be in a language that all stakeholders are familiar with and for those who are illiterate certain measures may need to be taken to ensure that they are fully aware of the contents of the disclosed documents Another important consideration is that ample time should be given to the stakeholders to review the disclosed information prior to the consultation process to allow them to thoroughly address the sub-projects various issues

29 The SPPP will also generate environmental benefits through a variety of other mechanisms among which are

(a)- Generation of environmental assessment guidelines that can be used by other organizations or ministries or could be adopted by the Ministry of Environment for more general use

(b)- Training of environmental specialists thus increasing the number of environmental professionals in the country

(c)- Improved environmental awareness in the local communities

b Future capacity building initiatives

30 These could be done through a structured training along two parallel lines (i) at the level of the implementing agencies when these are guided one by one through the process by the environmental specialist to help them look at the needed assessment and the mitigation measures if any (ii) at the level of the community by organizing awareness campaigns targeted to LCP and other prominent figures and other interested CSOs on environmental issues of relevance and how that affects the sub-projects implemented in their areas That creates a social accountability system that could be used to ensure that the sub-projects are implemented according to appropriate procedures

32 Negative Environmental Impacts

321 Overview of Negative Environmental Impacts

31 The SPPP will finance a considerable number of different types of subprojects An important percentage of the funding will be allocated for social development Though intended to improve environmental and social conditions these subprojects can have a variety of negative environmental impacts that might be encountered during the operation of the subprojects Environmental impacts arising from the operation of the different subprojects can be minimized by appropriate site selection good engineering design and appropriate construction techniques

4 IMPLEMENTATION ARRANGEMENTS

41 Environmental Guidelines

18

32 The implementation of the SPPP falls under the responsibility of MOSA who would be in charge of coordinating the various activities through its Social Development Centers (SDCs) with concerned local governments and NGOs A Project Coordination Team (PCT) will be established and would comprise experts with relevant experience in implementing similar projects and with proven capacity to handle all functions required in such a project Among its mandates the PCT will ensure that any sponsored subproject is environmentally sound and sustainable

33 The PCT shall ensure the following

Environmental considerations will be included as criteria for selecting activities to be supported by the project environmental assessment would become an integral part of the project cycle of any subproject

Environmental guidelines are followed and used throughout the project cycle

Environmental issues are introduced to beneficiaries through education and promotion of environmentally beneficial subprojects

34 The execution of the CSD will be undertaken by Civil Society Organizations (CSO) who would consist of qualified local authorities or national NGOs with strong community ties and proven execution capacity The SDC would assist local NGOs LCF and communities in identifying local needs preparing subprojects coordinating with concerned ministries and implementing the subprojects

42 Environmental Assessment (EA)

35 The World Bank Operational Policy (OP 401) on Environmental Assessment (January 1999) defines the Bankrsquos environmental assessment requirements to ensure that funded sub-projects are environmentally sound and sustainable A screening process is undertaken for all funded sub-projects to assess the magnitude and adversity of predicted environmental impacts and to determine the appropriate extent and type of EA Depending on the type location sensitivity and scale of the project as well as the nature and magnitude of environmental impacts sub-projects are classified into one of three categories

(a)- Category A Sub-Projects that are likely to cause significant and possibly irremediable environmental impacts

(b)- Category B Sub-Projects that might cause lesser adverse impacts than those of Category A and the impacts are often remediable or could be mitigated for

(c)- Category C Sub-Projects which could have minimal or no adverse environmental impacts

19

36 The SPPP will only fund sub-projects that can be classified as either Category B or Category C only For instance all income enhancement sub-projects will be classified as Category C while most social sub-projects will be Category B Sub-projects that are likely to cause substantial negative impacts and are expected to fall in Category A will not be approved for funding

37 This document will provide guidance with respect to the preparation of environmental assessment for the various funded subprojects These guidelines are based on the World Bank Operational Policies (OP 401) the Environmental Assessment Source book (1991) and its updates in addition to the Decree 86332012 on EA issued by the GOL

5 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

51 Objectives and Structure of the ESMP

38 The objectives of the ESMP are to mitigate the adverse environmental impacts identified in the SPPP The ESMP will consist of three kinds of activities

o Implementation of mitigation measures o Strengthening the capacities of PCT SDCs and local NGOs o Monitoring and evaluation of mitigation measures identified during subproject

formulation or within the environmental assessment report

52 Implementation of Mitigation Measures

39 Mitigation measures identified (Table 1) are for typical sub-projects and MOSAPCT will ensure that such measures are adhered to during the overall implementation of the SPPP

Table 1 Potential Environmental Impacts and Proposed Mitigation Measures for Different Subprojects

Project Component

Potential Impacts Mitigation Measures Responsibility

Roads rehabilitation

Clogging of natural drainage channelsEncroachment on private property

Dumping of construction wastes and accidental spills of machine fuels etcRisk of damage to unknown archaeological sites

Maintain ditches

Detailed property boundary surveys and flagging in fieldProper disposal of construction wastes

Use ldquochance findrdquo procedures and coordinate with appropriate

Contractor

ContractorIA

Contractor

IAsArcheology department

20

government agency

Rehabilitation of schools

Rehabilitation of health clinics

Irrigation and drainage

Improper disposal of wastes

Water quality degradation in ponds and reservoirsClogging of canals from weedssedimentsInefficient water flow because of heavy sedimentation

Degradation of water systems receiving irrigation waters by nutrients agrochemical and salts

Proper disposal of solid wastesPriority given to rehabilitation of toiletsInstallation of sanitation (cesspools)

Containerize infectious wastesPublic health awareness

Monitoring of water qualityOperation amp maintenance planProper design of canals and provision of access for weed and sediments removal

Control of agrochemical use

IAsMunicipality

IAscommunity

IAscommunity

Ministry of Health

Ministry of Energy and Water

IAs community

ContractorIAs

Ministry of Agriculturecommunity

53 Training Program and Capacity Building

40 The MOSA lacks the capacities and the expertise to work in the field of environmental monitoring and protection Moreover it is expected that the IAs mostly CSOs and SDCs do not have the needed resources to undertake the requirements needed in terms of EAs and designing mitigation measures This would require a detailed capacity building program that targets all levels of the decision making process in the project The central team at the MOSA and the PCT need to be oriented to the general approach to environmental safeguards importance use and how that could affect the selection implementation and monitoring of Sub-projects SDFCs and IAs should be trained on

21

the technical aspects of detection and mitigation and how these could be imbedded within the process of project identification to formulation to implementation These safeguards will have to be an integral part of any sub-project proposal and consequently any detailed action plan for any specific sub-project Environmental expertise within the implementing and executing bodies will be strengthened Training programs will designed and implemented with the assistance of a local or international expert and will target levels as stated in the Table 2 page 20

41 PCT and IAs At the initiation of the CSD and prior to bidding and selection of IAs a workshop will be provided and will include an environmental session to raise environmental awareness and to clarify the specific environmental requirements related to design and implementation of the SPPP

42 Another training workshop will be provided to the PCT and selected IAs and will cover the following to IAs

EIA techniques Screening sub-projects for environmental review Use of practical formschecklists Best environmental practices in design and implementation of projects Effective implementation of mitigation measures Project supervision Monitoring and evaluation

43 Local NGOs and Contractors IAs will be required to provide workshops for local NGOs and contractors focusing on public awareness case studies of environmental issues experienced in similar projects use of environmental guidelines and implementation of mitigation measures (Table 2 Annex III)

22

Table 2 Training and Capacity Building Program for Implementing the ESAFTraining

Capacity BuildingParticipating Stakeholders

Skills acquired Scheduling Cost Source

ManagementInstitutional

1year

SPPP manager MOSA central unit Head of concerned

departments at MOSA PCT

Decision making and delegation Work procedures Environmental awareness National guidelines WB guidelines Classification and mitigation

Prior to sub-project preparation Planning phase Refresher every 3 months as we

go along the project

Undertaken by the Environmental

SpecialistMiscellaneous

7500 USD

WBMOSA

Institutional at Intermediate levels

2 training sessions of 2 days year

(for SDC and IA X5 regions)

PCT Emanating committee SDC managers IAs

Environmental and social policies

Laws and regulations GOL and WB safeguards Evaluation and selection

During sub-project preparation Planning phase Sub-project evaluation

Undertaken by the Environmental

SpecialistMiscellaneous

30000 USD

WB MOSA

Implementation1 day session X2 year X 5 regions

IAs SDC staff Beneficiaries Municipalities

Environment and social tools Screening amp monitoring

methods Sustainability of the process Practical mitigation and

safeguards

During sub-project preparation Mobilization Implementation

Undertaken by the Environmental

SpecialistMiscellaneous

50000 USD

WB MOSA

Monitoring Evaluation and

Reporting1 dayX2 year X5

regions

IAs SDC staff Beneficiaries

Municipalities

Environmental and social monitoring and compliance

Progress report preparation Monitoring and Evaluation

During sub-project preparation MobilizationImplementation

Environmental Specialist + consultant

50000 USD

WB MOSA

Total 137500 USD (includes in kind contribution from MOSA)

23

54 Environmental Monitoring

44 Environmental Monitoring will be the responsibility of the ES PCT and MOSA Central Unit with the supervision of the LCP and will include compliance monitoring during implementation and also monitoring of significant impacts during the operation of the subproject

Table 3 Typical Examples of Monitoring Plan for the Operation of Different Subprojects

Sub-project Monitoring Indicators Responsibility FrequencyRoads rehabilitation

Operating drainage channels

NGOs in close coordination with local community

Semi-annual assessment

Improvements to Water Supply and Sanitation Facilities

Irrigation and drainage

Distribution network without leaksNo leakage or overflows of manholes or drainsWater Quality Monitoring

Irrigation network without leaksDrainage channels clean and properly maintainedWater quality parameters (pH COD BOD SS)

NGOs in close coordination with local community

Ministry of Health and Ministry of Energy and Water

NGOs in close coordination with local community

Testing by Ministry of Health and Ministry of Energy and Water

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Rehabilitation of schools

Rehabilitation of health clinics

Toilet facilities clean and functioning properlyDrinking water faucets clean and safe from contamination

NGOs in close coordination with local community and appropriate municipality

Ministry of Health in close coordination with local community

Semi-annual assessment

Semi-annual assessment

23

24

45 The Environmental Specialist (ES) of the PCT will also conduct periodic monitoring by visiting the sites of the various sub-projects at least twice during the implementation period of the sub-project

46 Monitoring indicators shall be developed for both the mobilization and the operation phase of the subprojects Monitoring of activities will have to ensure that mitigation measures of operations impacts are being implemented properly while the monitoring of operation is to ensure that no unforeseen negative impacts are arising

55 Sub-project Cycle

47 Component 2 of the SPPP is the Community Social Development Program (CSD) which will be financing community-based sub-projects through grants The Program will have two windows one for social services whereas the other is for Income Generation Activities (IGA) support with the review and approval mechanisms in large part being the same for both windows While Component 3 focuses on Poverty Targeting thus the services provided will have no impact on the environment component 1 will focus on the provision of technology and training to SDCs

48 Applicants will be invited to use standard forms (available on the MOSA website and upon request from SDCs) to submit proposals to the relevant SDC in cases where the applicant is the SDC itself the application will be submitted directly to the CSD program team in Beirut

49 SDCs will immediately check all proposals for completeness and give a receipt to the applicant with a proposal number proposals found to be incomplete will be rejected with an explanation All complete proposals will be presented for discussion to the relevant Local Community Platform (LCP) or equivalent consultative body to obtain feedback on among other things the actual need (in case of social services) or likely market value (in the case of IGA) of the proposed activity the reputation of the applicant the likely sustainability of the proposed activity the preliminary classification of the project within environmental categories (the final classification will be pending on the decision of the environmental specialist within the PCT) any problematic aspect (conflict of interest etc) and the overall compliance of the proposal with the purposes of the program This feedback is not binding but will be taken into consideration when deciding whether or not to fund the proposal The CSD program team will carry out a detailed desk review of all complete proposals to assess their technical quality as well as the budget and time line suggested for the sub-project The environmental specialist member of the Project Coordinating Team (PCT) will review the proposal and prepare all needed documentation based on his classification of the sub-project

56 Screening of Sub-Projects

50 Each sub-project to be implemented by an IA will be subjected to an environmental screening Using the screening form (Form 1) environmental and social checklists for the proposed sub-projects will be screened by the environmental specialist to identify any potential adverse impacts

25

From an environmental standpoint the screening form may identify impacts form sub-projects the issue of solid waste disposal at the site of a sub-project may come out as a point to look at in terms of designing mitigation measures to avoid negative impacts The selection of adequate storage collection and proper disposal could be steps to consider carefully

57 The Environmental and Social Screening Process

51 The objectives of sub-project screening is to determine which activities are likely to have negative environmental and social impacts

571 Subproject Screening Procedures

52 The sub-projects funded under this project are generally categorized as Category B or C and screening mechanisms would ensure that any identified Category A sub-projects are not funded under the project Due to the fact that most Category B sub-projects are small-scale which do not result in adverse negative environmental impacts this will require an ESMP which has clear due diligence environmental and social procedures (including the setting out of institutional responsibilities timing and budget) for sub-projects The ESMP should take into consideration the applicable requirements under the Bankrsquos ten safeguard policies

572 Environmental Sub-Project Screening Checklistsforms

53 The Operation Manual (OM) should contain for each type of sub-project a simple environmental screening checklist (Form 1)) which poses a series of questions designed to identify risks to the environment The goal of the checklist (also called a screening or environmental data sheet) is to identify which sub-projects require more environmental information in the form of a site-specific ESMP or which can proceed without any special mitigation measures that is falling under category C

Form 1 Environmental Screening Check-list

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

7

1 INTRODUCTION

11 Background

This document constitutes an integral part of the Project Appraisal Document intended for a World Bank loan to the Government of Lebanon at a total value of USD 30 Million for the implementation of the Social Promotion and Protection Project (SPPP) It has been prepared to present the environmental requirements and guidelines for the SPPP that the Government of Lebanon is planning to initiate through the Ministry of Social Affairs (MOSA)

PROJECT DEVELOPMENT OBJECTIVES

A Project Development Objective

1 The development objective of SPPP is to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

Project Beneficiaries

2 The SPPP beneficiaries consist of the following three categories

(a) Poor and Vulnerable Households and Community Members The ultimate beneficiaries of the project include (a) vulnerable individuals and households (eg children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) who will have improved access to social services provided by SDCs (b) poor and vulnerable individuals who will receive assistance through income generating activities (IGAs) as well as others in the community who will find new employment or experience increased earnings stimulated by growth of IGAs and (c) the poor households who will be eligible to receive NPTP benefits

(b) MOSA The project will help strengthen MOSArsquos capacity to carry out its official mandate both at the central level and through the SDCs at the local levels In particular MOSA will be supported in managing the implementation of small projects using a community-based demand-driven and participatory approach so as to position itself as the main government actor for community development activities in the social sphere At the same time the continued implementation of the NPTP will help MOSA develop the skills needed for administering well-targeted and efficient social safety nets

(c) Civil Society Organizations (CSOs) CSOs will also benefit from the project as they will have an opportunity to improve their capacity to propose prepare and implement income-generating projects and social services at the community level

8

B Project Components

3 The SPPP will have the following four components (1) Social Development Centers (SDCs) (2) Community Social Development Program (CSD) (3) National Poverty Targeting Program (NPTP) and (4) Project Coordination Team (PCT) Component 1 which focuses on building the capacity of the SDCs is cross-cutting between Components 2 and 3 as the SDCs are the local implementing arms of MOSArsquos mandate Specifically both the CSD and NPTP programs rely on the SDCs for implementation

Component 1 Social Development Centers (SDCs) (US$952 million total cost of which US$908 million to be financed from the loan)

4 The objective of this component is to enhance the administrative and operational capacity of the SDCs to enable them to offer social services of improved quality and relevance This component will also include key cross-component functions such as monitoring and evaluation social accountability measures and communication outreach To achieve the above this component will consist of the following sub-components

(a) Equipping automating and electronically linking the SDCs to the central unit at MOSA The project will finance (i) necessary equipment and software to computerize systems and processes at the SDCs (eg creating databases) and to ensure proper processing of NPTP transactions (ii) the establishment of a computerized modular MIS with dedicated modules for the CSD and NPTP1 programs as well as for other core functions (eg procurement financial management) and accessible to both SDCs and the central MOSA unit (iii) internet connectivity between the SDCs and MOSA and (iv) small works and equipment to refurbish and rehabilitate the SDCs as needed

(b) Building and empowering the human resources of the SDCs The project will finance training of SDC staff including in (i) the use of new equipment and systems (ii) specific topics to support the implementation of the CSD and NPTP programs such as handling grievances writing proposals and applying case management and participatory approaches

(c) Community participation The project will finance capacity building and technical assistance for SDCs to (i) establish mechanisms at the SDC level to facilitate community consultation in the SDC catchment area in the form of ldquoLocal Consultative Platformsrdquo (LCP) and (ii) create inventories of local social service providers carry out social needs assessments and prioritization and establish referral systems to ensure that social services match community needs

(d) Monitoring and Evaluation Social Audits and Communication Outreach (see Section IV B for further details) The project will finance the development of a comprehensive MampE system relying primarily on the computerized MIS as well as training of MOSA staff and the project team to use it This will include assessing the performance of the present NPTP MampE system improving it as needed and

1 As an NPTP module is already in use any needed upgrading will be handled under the NPTP Component

9

carrying out short surveys on a regular basis (eg opinion polls) As part of the monitoring effort as well as to promote good governance this component will finance social audits Communication outreach campaigns for the NPTP and the CSD programs will also be supported

Component 2 Community Social Development Program (CSD) (US$1729 million total cost of which US$1232 million to be financed from the loan)

5 This component aims to establish a transparent accountable and efficient national CSD program that will finance community-based sub-projects through grants The CSD program is designed building on the experience of the World Bank-supported Community Development Project (2001-2008) MOSA experiences as well as lessons learnt from other CDD programs in Lebanon and around the world Grant sizes are limited to US$50000 equivalent implementation time for each sub-grant is one year and beneficiaries will be required to make contributions upfront Targeting will be done according to two criteria (a) geographic targeting to prioritize areas of greater poverty and deprivation (eg Akkar district) based on information from updated poverty estimates and studies carried out by various donors (eg the European Union) and (b) categorical targeting to prioritize vulnerable groups (eg the handicapped) based on MOSArsquos mandate The component will consist of the following two sub-components

(a) Establishment of a National Community Social Development Program in MOSA the project will finance technical assistance in the form of key experts (eg CSD program manager engineer social specialist income-generating specialist) who will manage a transparent process of calls for proposals screening and prioritization of proposals and monitoring and supervision of sub-grant implementation

(b) Funding community-driven sub-projects The project will provide grants to eligible applicants (primarily SDCs and CSO) whose projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

10

Component 3 National Poverty Targeting Program (NPTP) (US$17286 million total cost of which US$665 million to be financed from the loan)

6 This component aims to expand the coverage from approximately 100300 (expected in 2013 baseline of SPPP) to 238700 (in 2018) individual beneficiaries as well as to improve the efficiency of the NPTP To achieve this objective the project will provide technical support for the continued roll-out and institutionalization of the NPTP which was launched in 2011 under the Bank-financed Second Emergency Social Protection Implementation Support Project (ESPISP II) Presently NPTP benefits consist of waived school and hospitalization fees coverage of chronic disease medications free schoolbooks and discounts on electricity bills The cost of these benefits as well as that of the SDC social workers involved in administering the program are being borne and will continue to be borne by the Government2 To achieve its objective this component will consist of the following three sub-components

(a) Continued roll-out and institutionalization The project will finance technical assistance for (i) supporting the program management team (ii) refining the program application forms and Proxy-Mean Testing (PMT) questionnaire (iii) upgrading the MIS module for the NPTP and establishing an archiving system (iv) adopting measures to prevent and discourage fraud and corruption (v) refining the grievance and redress mechanism for improved efficiency and transparency

(b) Access to social safety nets The project will finance technical assistance for (i) assessing the performance of the reimbursement mechanism of the NPTP benefits and designing any improvements and (ii) designing and piloting a case management approach with NPTP beneficiary households

(c) Enabling evidence-based policy making for poverty reduction The project will finance (i) technical assistance to support the Inter-ministerial Committee for Social Policy (Social-IMC) and its Secretariat (ii) technical assistance to establish a Poverty Analysis Team whose role will be to assess the poverty and inequality situation in Lebanon using Household Budget Survey (HBS) data and (iii) the design and implementation of the next HBS (in 2017) which will be a large-sample survey representative at the governorate (mohafazat) level

Component 4 Project Coordination Team (PCT) (US$214 million out of which US$195 from the loan)

7 The project will finance a team who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components (see Section III and Annex IV of the Project Appraisal Document) reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively

2 The Council of Ministers allocated US$28 million in 2011 to finance the benefits and approximately US$4 million for the hiring of 350 social workers

11

contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management

12 IMPLEMENTATION

a Institutional and Implementation Arrangements

8 MOSA is the project implementing agency and it will oversee the implementation of all SPPP activities A Project Coordinator will head the PCT and also be responsible for the implementation of Component 1 assisted by a Project Officer while Components 2 and 3 will each be headed by a Program Manager These positions will be financed by project funds A combination of contracted and MOSA staff will be responsible for the implementation of component activities

9 Each component will be overseen by a MOSA committee that will report to the Minister In the case of Components 2 and 3 the committee will be an ldquoEmanating Project Committeerdquo3 which will check the legal aspect of all activities financed and implemented by the component (which is considered an ldquoemanating projectrdquo) and oversee the way the funds are being spent In the case of Component 1 the committee will be a SDC Committee consisting of the SDC Director and other MOSA staff4

10 The heads of the components and the MOSA Minister (as well as the Director General if the position is filled) will form the SPPP Steering Committee which will meet periodically to review implementation progress and ensure coherence with ministry policies At the national policy level the Social Inter-Ministerial Committee (Social-IMC) with MOSA acting as its Technical Secretariat will ensure coordination of the SPPP with other social policies5 Further details are provided in Annex 3 of the Loan Agreement

11 With respect to the institutional setup of the NPTP the program has been operating under a ldquodual managementrdquo by MOSA and the Presidency of the Council of Ministers (PCM)6 This was deemed the best option at the time of appraisal of the ESPISP II project which supported the

3Emanating Project Committees are established as a way to circumvent the cumbersome Lebanese bureaucracy while still providing appropriate oversight They generally comprise five or six members taken from high-ranking positions within the Ministry (eg Department Directors)4 Each SDC has its own Emanating Committee so it would not be possible to also have an Emanating Committee overseeing the component5The Social-IMC established on January 22 2007 by a decree signed by the Prime Minister and composed of the Ministers of Finance Social Affairs Health Education Labor Interior amp Municipal Affairs Economy amp Trade NSSF and the President of CDR is charged with (i) drafting a comprehensive integrated and coordinated social strategy (ii) coordinating government activities for the provisions of social services (iii) ensuring coordination of all studies surveys reports related to social affairs and ensuring availability of relevant social data and indicators (iv) overseeing the implementation of social safety net programs and (v) coordinating monitoring and evaluating development programs that are financed by local and international partners6 This dual management consists of a central management unit at the PCM and Management central unit in MOSA The former is responsible for (i) co-managing the central NPTP database (ii) validating data and cross-checking with national databases (iii) processing household data and generating scores and ranks according to the proxy-means testing (PMT) formula (iv) maintaining the PMT formula (v) analyzing national data and reporting findings to the Social Inter-Ministerial Committee (Social-IMC) (vi) monitoring the NPTP targeting and (vii) auditing data processing The central unit in MOSA (through its SDCs)is responsible for (i) co-managing the central NPTP database (ii) receiving household applications (iii) interfacing with applicants (iv) entering data (v) conducting household visits (vi) checking for data errors (vii) transmitting data to the central database of the NPTP CMU and (viii) managing the public relations campaign

12

creation of the NPTP7 The present institutional setup will be retained during the implementation of the SPPP though the GOL has started discussing the possibility of consolidating the NPTP under MOSA and institutionalizing it as an independent program with its own budgetary allocations

This document is intended to look at designing the Environmental and Social Assessment Framework (ESAF) for the sub-projects to be financed under Component 2 of the SPPP

b Purpose of the Environmental and Social Assessment Framework (ESAF)

12 The ESAF is designed to ensure protection of the health and livelihood of beneficiaries and the environment The framework is intended to protect against both local impacts of individual sub-projects and the cumulative impact of many similar subprojects in the same area

13 Although many sub-projects have little or no adverse impact it is important nonetheless to acknowledge the possible unfavorable effects Experience shows that CDD projects need to establish simple social and environmental assessment procedures to avoid causing adverse harm to human health and the environment

14 The main elements of the Environmental and Social Assessment Framework (ESAF)are described below

Tools These tools usually include guidance written in the local language and presented in a form easily understood by community facilitators as well as

(i) rules-based social and environmental criteria establishing basic dorsquos and donrsquots and indicating the permissions and clearances required for common activities and(ii) mitigation guidelines providing practical guidance for the avoidance or mitigation of potential environmental impacts and identifying issues for which more specific expert guidance should be sought

Implementation Arrangements A description of roles and responsibilities to ensure that the identification avoidance and mitigation of environmental and social risks should be built into sub-project preparation appraisal and supervision This normally includes roles at the levels of community facilitators local management and program-wide management These should also be reflected in any Operational Manual that is prepared This description should abide by the rules and regulations issued by the Ministry of Environment

Capacity Building Training must be provided to ensure that every person with a role in the safeguard implementation arrangements is able to fulfill their responsibilities It is important that training in environmental and social safeguards management is incorporated from the very start of the program before the preparation of sub-projects begins

Supervision and Monitoring Arrangements should be in place to supervise both the adequacy and application of the safeguard management tools In addition it is useful to keep track of environmental concerns in program areas so that more specific mitigation measures can be

7Other options were considered at the time and are detailed in the EPP of the ESPISP II

13

designed and opportunities for enhancements can be promoted Secondary information gathering is usually sufficient for this purpose

Audit During preparation of the program it is useful to agree that an independent audit of the ESAF will be undertaken at mid-term to draw lessons and recommend improvements

15 Experience has shown the value of involving environmental organizations particularly those with advocacy expertise in the design of the Environmental and Social Assessment Frameworks and subsequently in the associated capacity building supervision and monitoring This in fact was done through the consultation process as it will be documented in later sections of this document Access to environmental expertise can be facilitated during program implementation through the identification of local professionals with an environmental background who can form a resource pool to be mobilized locally as subprojects require

16 Social funds and CDD programs also provide important opportunities to promote pro-poor reforms in environmental policies particularly those associated with access to natural resources and their management The involvement of national and local environmental specialists can play a valuable role in advancing these agendas

17 A development project mitigation measures (Annex I) encompass all actions taken to eliminate offset or reduce potentially adverse environmental impacts to acceptable levels Such measures are typically associated with the latter stages of project planning although in practice they may occur at any stage throughout the project cycle Normally potential impacts are identified early during the initiation and scoping stages of EA for a project and measures to avoid or minimize impacts are incorporated into the alternatives being considered In this respect some of the most important measures to protect the environment or local communities become integral to the project design and are never reflected within a formal environmental and social management plan (ESMP) For example the environmental and social bases for choosing a preferred location for a project will not necessarily be evident within the ESMP

18 Environmental and Social Management Plans (ESMPs) outline the mitigation monitoring and institutional measures to be taken during sub-project implementation and operation to avoid or control adverse environmental impacts and the actions needed to implement these measures They provide a crucial link between alternative mitigation measures evaluated and described within the EA report and ensuring that such measures are implemented EA reports are essentially planning documents with no legal basis In many cases mitigation measures outlined in EAs are described in illustrative terms or have neither been committed to by the borrower nor reflected in the project design In this regard the ESMP is a basis for negotiation and reaching agreement with borrowers on a sub-projectrsquos key social and environmental performance standards

19 This report aims at providing guidance in identifying environmental assessment needs for the various sub-projects that are funded under Component 2 of the SPPP and might have the potential of inflicting environmental impacts that need to be addressedFunded sub-projects fall under two categories

14

(i) Social Development (a) improving access to specialized social services to satisfy the needs of vulnerable groups at risk including the disabled children youth women and the elderly (b) enhancing environmental protection initiatives such as reforestation and soil erosion control wells and spring protection and preservation of natural sites

(ii) Income Enhancement Capacity building activities to support (a) micro and small entrepreneurs and non-governmental organizations providing credit to target beneficiary groups and (b) women youth and disabled people in order to provide them with demand driven specialized skills to improve their income and enhance their business opportunities

2 POLICY LEGAL amp INSTITUTIONAL FRAMEWORK FOR THE ENVIRONMENT

21 Regulatory Framework for Environmental Impact Assessment

20 Presently the environmental framework of Lebanon is managed and supervised by the Ministry of Environment (MOE) that was created by law 216 of April 2nd 1993 to be the government institution responsible for the development of a national strategy for sustainable development This was strengthened through the Law 4442002 Framework Law for the Protection of the Environment and the CEA (Country Environmental Analysis) The MOE is undergoing several review procedures to up-date the countryrsquos environmental policies and regulations including the preparation of an Environmental Code issuance of an Environmental Impact Assessment (EIA) decree as well as norms and standards for environmental protection The Environmental codes as well as the EIA decree were prepared with the assistance of the World Bank under the Mediterranean Environmental Technical Assistance Program (METAP) Also the World Bank has financed through METAP an assessment of the EIA System in Lebanon (Annex II)

METAP has also supported the establishment of an Environmental Management System Unit (EMSU) dealing with EIA at the MOE The concept of EA as part of project planning in Lebanon is still new and has only recently gained some attention The Environmental Impact Assessment (EIA) decree that was prepared by the MOE will require that an EIA be prepared during the planning process of both public and private development projects in Lebanon

22 Existing Environmental Legislation

221 International Conventions

21 The Lebanese Government has ratified a large number of international conventions for Environmental Protection Among the most important ones are

The Barcelona Convention for the protection of the Mediterranean SEA International Convention on World Heritage Protection International Convention on Bio-diversity Protection United Nations Convention on Desertification Montreal Protocol for the protection of the Ozone layer

15

222 Existing Lebanese Legislations

22 A list of the most significant existing environmental legislation is given in Annex II The primary safeguards as they are likely to affect SPPP subprojects are summarized in the following sections

Natural LandscapeProtection of the natural landscape of Lebanon was first addressed under the Law of January 1949 Recently cutting of trees was severely restricted under Decree No142 of March 1993 and further protection was provided under Law No 550 dated July 1996 There are also a number of Laws and Decisions that were issued to protect sites of particularly valuable landscape by declaring them Natural Reserves

Soil Water and Air PollutionProtection against pollution was first addressed by Decree No 8735 of October 1974 that prohibited the digging of wells for the disposal of raw sewage banned infiltration from cesspools and the use of sewage for the irrigation of vegetables and some fruits Decision No 521 of July 1996 introduced measures to deal with the pollution of the air water and soil including national standards for drinking water bathing waters and wastewater quality Recently Decision No 81 dated March 2001completed and reviewed the previously issued standards

Water ResourcesGround and surface water resources have been protected since the introduction of Order No 144 dated June 1925 which covered the major springs that supply the countryrsquos potable and irrigation needs Zoning of water sources and recharging of catchment areas was introduced by Decree 10276 of October 1962 to cope with increasing demand for water In 1970 Decree 14438 established a limit on the depth and exploitation of unlicensed wells and boreholes 150 m and 100 m3d respectively

Archaeological and Historical SitesThe protection of archaeological and historic sites was first addressed in Law No 1666 of November 1933 Later legislation has been introduced to afford special protection to the Cultural Heritage World Heritage and Cultural Landscape Sites declared by UNESCO

Public StreetsLaw No 60 of September 1983 covers Work in public streets law No 98 of September 1989 and by Circular 695 issued by the Prime Ministerrsquos Office on March 1995

Decree 86332012 on EIA describes clearly the various measures that need to be considered in the preliminary Environmental Evaluation of any project Projects found to require further investigation will have to be subjected to an EIA whereby complete set of information is required to allow for the Ministry to suggest needed mitigation measures and issue accordingly needed permits The stipulations of the decree go in hand with most of the WB guidelines The decree describes the various categories of sub-projects that do

16

require EIA and what are the projects that might cause risks and hazards A copy of the decree will be attached as an Annex to this document

23 Permit Procedures

23 Depending on the type and size of the sub-project to be executed and according to the Lebanese legislation a number of approvals and permits might be required from various governmental agencies In view of their nature and scale the majority of the sub-projects that would be funded by the SPPP will only require the approval of the municipality and or the Ministry of Municipalities and Rural Affairs

3 POTENTIAL SIGNIFICANT ENVIRONMENTAL IMPACTS AND GOOD PRACTICE MITIGATION PROCEDURES

31 Positive Environnemental Impact

24 Most sub-projects financed by the SPPP that are well designed and properly implemented can have a positive impact on the environment The benefits of this type of sub-projects are often long term rather than short term and are not limited to the specific local community Examples of environmentally beneficial sub-projects that will be financed by the SPPP are subject to case by case assessment soil erosion protection protection of natural and cultural heritage sites

a Consultation and Public Disclosure

25 A simple approach is proposed for public consultation in the early stages of sub-project preparation and planning

The stakeholders should be made aware of the different elements and features of each sub-project and their main objectives and target groups Once an ESIA has been made the results of this study should be disclosed to all concerned primary stakeholders

The stakeholders should then be encouraged to share their concerns worries and any comments they have on the sub-project or its likely impacts This should include discussions on alternative and proposed mitigation measures that are to be accounted for in the sub-project design implementation and operation phases

The final step is to incorporate the stakeholder inputs into the sub-project plans in order to improve the sub-project design

26 The process of stakeholder involvement and consultation will continue during sub-project implementation as well in order to integrate any additional comments and worries that may arise from the construction and implementation phase

27 Consultation with the stakeholders may take different forms depending on the need and subject matter that is being communicated An informative method would be through the use of one-way communication techniques such as audio (radio) visual (television) printed (leaflets brochures pictures diagrams posters) or electronic media (internet and electronic mail) In this case the stakeholders will be merely informed with certain information and there shall be no opportunity for questions or comments In order to have interactive consultation with the

17

stakeholders two-way participatory techniques are required This may include one-to-one briefings small group and village meetings and the organization of workshops and forums

28 The technique used for the disclosure and dissemination of information and data should take into consideration stakeholder preferences and characteristics The disclosed information should be in a language that all stakeholders are familiar with and for those who are illiterate certain measures may need to be taken to ensure that they are fully aware of the contents of the disclosed documents Another important consideration is that ample time should be given to the stakeholders to review the disclosed information prior to the consultation process to allow them to thoroughly address the sub-projects various issues

29 The SPPP will also generate environmental benefits through a variety of other mechanisms among which are

(a)- Generation of environmental assessment guidelines that can be used by other organizations or ministries or could be adopted by the Ministry of Environment for more general use

(b)- Training of environmental specialists thus increasing the number of environmental professionals in the country

(c)- Improved environmental awareness in the local communities

b Future capacity building initiatives

30 These could be done through a structured training along two parallel lines (i) at the level of the implementing agencies when these are guided one by one through the process by the environmental specialist to help them look at the needed assessment and the mitigation measures if any (ii) at the level of the community by organizing awareness campaigns targeted to LCP and other prominent figures and other interested CSOs on environmental issues of relevance and how that affects the sub-projects implemented in their areas That creates a social accountability system that could be used to ensure that the sub-projects are implemented according to appropriate procedures

32 Negative Environmental Impacts

321 Overview of Negative Environmental Impacts

31 The SPPP will finance a considerable number of different types of subprojects An important percentage of the funding will be allocated for social development Though intended to improve environmental and social conditions these subprojects can have a variety of negative environmental impacts that might be encountered during the operation of the subprojects Environmental impacts arising from the operation of the different subprojects can be minimized by appropriate site selection good engineering design and appropriate construction techniques

4 IMPLEMENTATION ARRANGEMENTS

41 Environmental Guidelines

18

32 The implementation of the SPPP falls under the responsibility of MOSA who would be in charge of coordinating the various activities through its Social Development Centers (SDCs) with concerned local governments and NGOs A Project Coordination Team (PCT) will be established and would comprise experts with relevant experience in implementing similar projects and with proven capacity to handle all functions required in such a project Among its mandates the PCT will ensure that any sponsored subproject is environmentally sound and sustainable

33 The PCT shall ensure the following

Environmental considerations will be included as criteria for selecting activities to be supported by the project environmental assessment would become an integral part of the project cycle of any subproject

Environmental guidelines are followed and used throughout the project cycle

Environmental issues are introduced to beneficiaries through education and promotion of environmentally beneficial subprojects

34 The execution of the CSD will be undertaken by Civil Society Organizations (CSO) who would consist of qualified local authorities or national NGOs with strong community ties and proven execution capacity The SDC would assist local NGOs LCF and communities in identifying local needs preparing subprojects coordinating with concerned ministries and implementing the subprojects

42 Environmental Assessment (EA)

35 The World Bank Operational Policy (OP 401) on Environmental Assessment (January 1999) defines the Bankrsquos environmental assessment requirements to ensure that funded sub-projects are environmentally sound and sustainable A screening process is undertaken for all funded sub-projects to assess the magnitude and adversity of predicted environmental impacts and to determine the appropriate extent and type of EA Depending on the type location sensitivity and scale of the project as well as the nature and magnitude of environmental impacts sub-projects are classified into one of three categories

(a)- Category A Sub-Projects that are likely to cause significant and possibly irremediable environmental impacts

(b)- Category B Sub-Projects that might cause lesser adverse impacts than those of Category A and the impacts are often remediable or could be mitigated for

(c)- Category C Sub-Projects which could have minimal or no adverse environmental impacts

19

36 The SPPP will only fund sub-projects that can be classified as either Category B or Category C only For instance all income enhancement sub-projects will be classified as Category C while most social sub-projects will be Category B Sub-projects that are likely to cause substantial negative impacts and are expected to fall in Category A will not be approved for funding

37 This document will provide guidance with respect to the preparation of environmental assessment for the various funded subprojects These guidelines are based on the World Bank Operational Policies (OP 401) the Environmental Assessment Source book (1991) and its updates in addition to the Decree 86332012 on EA issued by the GOL

5 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

51 Objectives and Structure of the ESMP

38 The objectives of the ESMP are to mitigate the adverse environmental impacts identified in the SPPP The ESMP will consist of three kinds of activities

o Implementation of mitigation measures o Strengthening the capacities of PCT SDCs and local NGOs o Monitoring and evaluation of mitigation measures identified during subproject

formulation or within the environmental assessment report

52 Implementation of Mitigation Measures

39 Mitigation measures identified (Table 1) are for typical sub-projects and MOSAPCT will ensure that such measures are adhered to during the overall implementation of the SPPP

Table 1 Potential Environmental Impacts and Proposed Mitigation Measures for Different Subprojects

Project Component

Potential Impacts Mitigation Measures Responsibility

Roads rehabilitation

Clogging of natural drainage channelsEncroachment on private property

Dumping of construction wastes and accidental spills of machine fuels etcRisk of damage to unknown archaeological sites

Maintain ditches

Detailed property boundary surveys and flagging in fieldProper disposal of construction wastes

Use ldquochance findrdquo procedures and coordinate with appropriate

Contractor

ContractorIA

Contractor

IAsArcheology department

20

government agency

Rehabilitation of schools

Rehabilitation of health clinics

Irrigation and drainage

Improper disposal of wastes

Water quality degradation in ponds and reservoirsClogging of canals from weedssedimentsInefficient water flow because of heavy sedimentation

Degradation of water systems receiving irrigation waters by nutrients agrochemical and salts

Proper disposal of solid wastesPriority given to rehabilitation of toiletsInstallation of sanitation (cesspools)

Containerize infectious wastesPublic health awareness

Monitoring of water qualityOperation amp maintenance planProper design of canals and provision of access for weed and sediments removal

Control of agrochemical use

IAsMunicipality

IAscommunity

IAscommunity

Ministry of Health

Ministry of Energy and Water

IAs community

ContractorIAs

Ministry of Agriculturecommunity

53 Training Program and Capacity Building

40 The MOSA lacks the capacities and the expertise to work in the field of environmental monitoring and protection Moreover it is expected that the IAs mostly CSOs and SDCs do not have the needed resources to undertake the requirements needed in terms of EAs and designing mitigation measures This would require a detailed capacity building program that targets all levels of the decision making process in the project The central team at the MOSA and the PCT need to be oriented to the general approach to environmental safeguards importance use and how that could affect the selection implementation and monitoring of Sub-projects SDFCs and IAs should be trained on

21

the technical aspects of detection and mitigation and how these could be imbedded within the process of project identification to formulation to implementation These safeguards will have to be an integral part of any sub-project proposal and consequently any detailed action plan for any specific sub-project Environmental expertise within the implementing and executing bodies will be strengthened Training programs will designed and implemented with the assistance of a local or international expert and will target levels as stated in the Table 2 page 20

41 PCT and IAs At the initiation of the CSD and prior to bidding and selection of IAs a workshop will be provided and will include an environmental session to raise environmental awareness and to clarify the specific environmental requirements related to design and implementation of the SPPP

42 Another training workshop will be provided to the PCT and selected IAs and will cover the following to IAs

EIA techniques Screening sub-projects for environmental review Use of practical formschecklists Best environmental practices in design and implementation of projects Effective implementation of mitigation measures Project supervision Monitoring and evaluation

43 Local NGOs and Contractors IAs will be required to provide workshops for local NGOs and contractors focusing on public awareness case studies of environmental issues experienced in similar projects use of environmental guidelines and implementation of mitigation measures (Table 2 Annex III)

22

Table 2 Training and Capacity Building Program for Implementing the ESAFTraining

Capacity BuildingParticipating Stakeholders

Skills acquired Scheduling Cost Source

ManagementInstitutional

1year

SPPP manager MOSA central unit Head of concerned

departments at MOSA PCT

Decision making and delegation Work procedures Environmental awareness National guidelines WB guidelines Classification and mitigation

Prior to sub-project preparation Planning phase Refresher every 3 months as we

go along the project

Undertaken by the Environmental

SpecialistMiscellaneous

7500 USD

WBMOSA

Institutional at Intermediate levels

2 training sessions of 2 days year

(for SDC and IA X5 regions)

PCT Emanating committee SDC managers IAs

Environmental and social policies

Laws and regulations GOL and WB safeguards Evaluation and selection

During sub-project preparation Planning phase Sub-project evaluation

Undertaken by the Environmental

SpecialistMiscellaneous

30000 USD

WB MOSA

Implementation1 day session X2 year X 5 regions

IAs SDC staff Beneficiaries Municipalities

Environment and social tools Screening amp monitoring

methods Sustainability of the process Practical mitigation and

safeguards

During sub-project preparation Mobilization Implementation

Undertaken by the Environmental

SpecialistMiscellaneous

50000 USD

WB MOSA

Monitoring Evaluation and

Reporting1 dayX2 year X5

regions

IAs SDC staff Beneficiaries

Municipalities

Environmental and social monitoring and compliance

Progress report preparation Monitoring and Evaluation

During sub-project preparation MobilizationImplementation

Environmental Specialist + consultant

50000 USD

WB MOSA

Total 137500 USD (includes in kind contribution from MOSA)

23

54 Environmental Monitoring

44 Environmental Monitoring will be the responsibility of the ES PCT and MOSA Central Unit with the supervision of the LCP and will include compliance monitoring during implementation and also monitoring of significant impacts during the operation of the subproject

Table 3 Typical Examples of Monitoring Plan for the Operation of Different Subprojects

Sub-project Monitoring Indicators Responsibility FrequencyRoads rehabilitation

Operating drainage channels

NGOs in close coordination with local community

Semi-annual assessment

Improvements to Water Supply and Sanitation Facilities

Irrigation and drainage

Distribution network without leaksNo leakage or overflows of manholes or drainsWater Quality Monitoring

Irrigation network without leaksDrainage channels clean and properly maintainedWater quality parameters (pH COD BOD SS)

NGOs in close coordination with local community

Ministry of Health and Ministry of Energy and Water

NGOs in close coordination with local community

Testing by Ministry of Health and Ministry of Energy and Water

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Rehabilitation of schools

Rehabilitation of health clinics

Toilet facilities clean and functioning properlyDrinking water faucets clean and safe from contamination

NGOs in close coordination with local community and appropriate municipality

Ministry of Health in close coordination with local community

Semi-annual assessment

Semi-annual assessment

23

24

45 The Environmental Specialist (ES) of the PCT will also conduct periodic monitoring by visiting the sites of the various sub-projects at least twice during the implementation period of the sub-project

46 Monitoring indicators shall be developed for both the mobilization and the operation phase of the subprojects Monitoring of activities will have to ensure that mitigation measures of operations impacts are being implemented properly while the monitoring of operation is to ensure that no unforeseen negative impacts are arising

55 Sub-project Cycle

47 Component 2 of the SPPP is the Community Social Development Program (CSD) which will be financing community-based sub-projects through grants The Program will have two windows one for social services whereas the other is for Income Generation Activities (IGA) support with the review and approval mechanisms in large part being the same for both windows While Component 3 focuses on Poverty Targeting thus the services provided will have no impact on the environment component 1 will focus on the provision of technology and training to SDCs

48 Applicants will be invited to use standard forms (available on the MOSA website and upon request from SDCs) to submit proposals to the relevant SDC in cases where the applicant is the SDC itself the application will be submitted directly to the CSD program team in Beirut

49 SDCs will immediately check all proposals for completeness and give a receipt to the applicant with a proposal number proposals found to be incomplete will be rejected with an explanation All complete proposals will be presented for discussion to the relevant Local Community Platform (LCP) or equivalent consultative body to obtain feedback on among other things the actual need (in case of social services) or likely market value (in the case of IGA) of the proposed activity the reputation of the applicant the likely sustainability of the proposed activity the preliminary classification of the project within environmental categories (the final classification will be pending on the decision of the environmental specialist within the PCT) any problematic aspect (conflict of interest etc) and the overall compliance of the proposal with the purposes of the program This feedback is not binding but will be taken into consideration when deciding whether or not to fund the proposal The CSD program team will carry out a detailed desk review of all complete proposals to assess their technical quality as well as the budget and time line suggested for the sub-project The environmental specialist member of the Project Coordinating Team (PCT) will review the proposal and prepare all needed documentation based on his classification of the sub-project

56 Screening of Sub-Projects

50 Each sub-project to be implemented by an IA will be subjected to an environmental screening Using the screening form (Form 1) environmental and social checklists for the proposed sub-projects will be screened by the environmental specialist to identify any potential adverse impacts

25

From an environmental standpoint the screening form may identify impacts form sub-projects the issue of solid waste disposal at the site of a sub-project may come out as a point to look at in terms of designing mitigation measures to avoid negative impacts The selection of adequate storage collection and proper disposal could be steps to consider carefully

57 The Environmental and Social Screening Process

51 The objectives of sub-project screening is to determine which activities are likely to have negative environmental and social impacts

571 Subproject Screening Procedures

52 The sub-projects funded under this project are generally categorized as Category B or C and screening mechanisms would ensure that any identified Category A sub-projects are not funded under the project Due to the fact that most Category B sub-projects are small-scale which do not result in adverse negative environmental impacts this will require an ESMP which has clear due diligence environmental and social procedures (including the setting out of institutional responsibilities timing and budget) for sub-projects The ESMP should take into consideration the applicable requirements under the Bankrsquos ten safeguard policies

572 Environmental Sub-Project Screening Checklistsforms

53 The Operation Manual (OM) should contain for each type of sub-project a simple environmental screening checklist (Form 1)) which poses a series of questions designed to identify risks to the environment The goal of the checklist (also called a screening or environmental data sheet) is to identify which sub-projects require more environmental information in the form of a site-specific ESMP or which can proceed without any special mitigation measures that is falling under category C

Form 1 Environmental Screening Check-list

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

8

B Project Components

3 The SPPP will have the following four components (1) Social Development Centers (SDCs) (2) Community Social Development Program (CSD) (3) National Poverty Targeting Program (NPTP) and (4) Project Coordination Team (PCT) Component 1 which focuses on building the capacity of the SDCs is cross-cutting between Components 2 and 3 as the SDCs are the local implementing arms of MOSArsquos mandate Specifically both the CSD and NPTP programs rely on the SDCs for implementation

Component 1 Social Development Centers (SDCs) (US$952 million total cost of which US$908 million to be financed from the loan)

4 The objective of this component is to enhance the administrative and operational capacity of the SDCs to enable them to offer social services of improved quality and relevance This component will also include key cross-component functions such as monitoring and evaluation social accountability measures and communication outreach To achieve the above this component will consist of the following sub-components

(a) Equipping automating and electronically linking the SDCs to the central unit at MOSA The project will finance (i) necessary equipment and software to computerize systems and processes at the SDCs (eg creating databases) and to ensure proper processing of NPTP transactions (ii) the establishment of a computerized modular MIS with dedicated modules for the CSD and NPTP1 programs as well as for other core functions (eg procurement financial management) and accessible to both SDCs and the central MOSA unit (iii) internet connectivity between the SDCs and MOSA and (iv) small works and equipment to refurbish and rehabilitate the SDCs as needed

(b) Building and empowering the human resources of the SDCs The project will finance training of SDC staff including in (i) the use of new equipment and systems (ii) specific topics to support the implementation of the CSD and NPTP programs such as handling grievances writing proposals and applying case management and participatory approaches

(c) Community participation The project will finance capacity building and technical assistance for SDCs to (i) establish mechanisms at the SDC level to facilitate community consultation in the SDC catchment area in the form of ldquoLocal Consultative Platformsrdquo (LCP) and (ii) create inventories of local social service providers carry out social needs assessments and prioritization and establish referral systems to ensure that social services match community needs

(d) Monitoring and Evaluation Social Audits and Communication Outreach (see Section IV B for further details) The project will finance the development of a comprehensive MampE system relying primarily on the computerized MIS as well as training of MOSA staff and the project team to use it This will include assessing the performance of the present NPTP MampE system improving it as needed and

1 As an NPTP module is already in use any needed upgrading will be handled under the NPTP Component

9

carrying out short surveys on a regular basis (eg opinion polls) As part of the monitoring effort as well as to promote good governance this component will finance social audits Communication outreach campaigns for the NPTP and the CSD programs will also be supported

Component 2 Community Social Development Program (CSD) (US$1729 million total cost of which US$1232 million to be financed from the loan)

5 This component aims to establish a transparent accountable and efficient national CSD program that will finance community-based sub-projects through grants The CSD program is designed building on the experience of the World Bank-supported Community Development Project (2001-2008) MOSA experiences as well as lessons learnt from other CDD programs in Lebanon and around the world Grant sizes are limited to US$50000 equivalent implementation time for each sub-grant is one year and beneficiaries will be required to make contributions upfront Targeting will be done according to two criteria (a) geographic targeting to prioritize areas of greater poverty and deprivation (eg Akkar district) based on information from updated poverty estimates and studies carried out by various donors (eg the European Union) and (b) categorical targeting to prioritize vulnerable groups (eg the handicapped) based on MOSArsquos mandate The component will consist of the following two sub-components

(a) Establishment of a National Community Social Development Program in MOSA the project will finance technical assistance in the form of key experts (eg CSD program manager engineer social specialist income-generating specialist) who will manage a transparent process of calls for proposals screening and prioritization of proposals and monitoring and supervision of sub-grant implementation

(b) Funding community-driven sub-projects The project will provide grants to eligible applicants (primarily SDCs and CSO) whose projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

10

Component 3 National Poverty Targeting Program (NPTP) (US$17286 million total cost of which US$665 million to be financed from the loan)

6 This component aims to expand the coverage from approximately 100300 (expected in 2013 baseline of SPPP) to 238700 (in 2018) individual beneficiaries as well as to improve the efficiency of the NPTP To achieve this objective the project will provide technical support for the continued roll-out and institutionalization of the NPTP which was launched in 2011 under the Bank-financed Second Emergency Social Protection Implementation Support Project (ESPISP II) Presently NPTP benefits consist of waived school and hospitalization fees coverage of chronic disease medications free schoolbooks and discounts on electricity bills The cost of these benefits as well as that of the SDC social workers involved in administering the program are being borne and will continue to be borne by the Government2 To achieve its objective this component will consist of the following three sub-components

(a) Continued roll-out and institutionalization The project will finance technical assistance for (i) supporting the program management team (ii) refining the program application forms and Proxy-Mean Testing (PMT) questionnaire (iii) upgrading the MIS module for the NPTP and establishing an archiving system (iv) adopting measures to prevent and discourage fraud and corruption (v) refining the grievance and redress mechanism for improved efficiency and transparency

(b) Access to social safety nets The project will finance technical assistance for (i) assessing the performance of the reimbursement mechanism of the NPTP benefits and designing any improvements and (ii) designing and piloting a case management approach with NPTP beneficiary households

(c) Enabling evidence-based policy making for poverty reduction The project will finance (i) technical assistance to support the Inter-ministerial Committee for Social Policy (Social-IMC) and its Secretariat (ii) technical assistance to establish a Poverty Analysis Team whose role will be to assess the poverty and inequality situation in Lebanon using Household Budget Survey (HBS) data and (iii) the design and implementation of the next HBS (in 2017) which will be a large-sample survey representative at the governorate (mohafazat) level

Component 4 Project Coordination Team (PCT) (US$214 million out of which US$195 from the loan)

7 The project will finance a team who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components (see Section III and Annex IV of the Project Appraisal Document) reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively

2 The Council of Ministers allocated US$28 million in 2011 to finance the benefits and approximately US$4 million for the hiring of 350 social workers

11

contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management

12 IMPLEMENTATION

a Institutional and Implementation Arrangements

8 MOSA is the project implementing agency and it will oversee the implementation of all SPPP activities A Project Coordinator will head the PCT and also be responsible for the implementation of Component 1 assisted by a Project Officer while Components 2 and 3 will each be headed by a Program Manager These positions will be financed by project funds A combination of contracted and MOSA staff will be responsible for the implementation of component activities

9 Each component will be overseen by a MOSA committee that will report to the Minister In the case of Components 2 and 3 the committee will be an ldquoEmanating Project Committeerdquo3 which will check the legal aspect of all activities financed and implemented by the component (which is considered an ldquoemanating projectrdquo) and oversee the way the funds are being spent In the case of Component 1 the committee will be a SDC Committee consisting of the SDC Director and other MOSA staff4

10 The heads of the components and the MOSA Minister (as well as the Director General if the position is filled) will form the SPPP Steering Committee which will meet periodically to review implementation progress and ensure coherence with ministry policies At the national policy level the Social Inter-Ministerial Committee (Social-IMC) with MOSA acting as its Technical Secretariat will ensure coordination of the SPPP with other social policies5 Further details are provided in Annex 3 of the Loan Agreement

11 With respect to the institutional setup of the NPTP the program has been operating under a ldquodual managementrdquo by MOSA and the Presidency of the Council of Ministers (PCM)6 This was deemed the best option at the time of appraisal of the ESPISP II project which supported the

3Emanating Project Committees are established as a way to circumvent the cumbersome Lebanese bureaucracy while still providing appropriate oversight They generally comprise five or six members taken from high-ranking positions within the Ministry (eg Department Directors)4 Each SDC has its own Emanating Committee so it would not be possible to also have an Emanating Committee overseeing the component5The Social-IMC established on January 22 2007 by a decree signed by the Prime Minister and composed of the Ministers of Finance Social Affairs Health Education Labor Interior amp Municipal Affairs Economy amp Trade NSSF and the President of CDR is charged with (i) drafting a comprehensive integrated and coordinated social strategy (ii) coordinating government activities for the provisions of social services (iii) ensuring coordination of all studies surveys reports related to social affairs and ensuring availability of relevant social data and indicators (iv) overseeing the implementation of social safety net programs and (v) coordinating monitoring and evaluating development programs that are financed by local and international partners6 This dual management consists of a central management unit at the PCM and Management central unit in MOSA The former is responsible for (i) co-managing the central NPTP database (ii) validating data and cross-checking with national databases (iii) processing household data and generating scores and ranks according to the proxy-means testing (PMT) formula (iv) maintaining the PMT formula (v) analyzing national data and reporting findings to the Social Inter-Ministerial Committee (Social-IMC) (vi) monitoring the NPTP targeting and (vii) auditing data processing The central unit in MOSA (through its SDCs)is responsible for (i) co-managing the central NPTP database (ii) receiving household applications (iii) interfacing with applicants (iv) entering data (v) conducting household visits (vi) checking for data errors (vii) transmitting data to the central database of the NPTP CMU and (viii) managing the public relations campaign

12

creation of the NPTP7 The present institutional setup will be retained during the implementation of the SPPP though the GOL has started discussing the possibility of consolidating the NPTP under MOSA and institutionalizing it as an independent program with its own budgetary allocations

This document is intended to look at designing the Environmental and Social Assessment Framework (ESAF) for the sub-projects to be financed under Component 2 of the SPPP

b Purpose of the Environmental and Social Assessment Framework (ESAF)

12 The ESAF is designed to ensure protection of the health and livelihood of beneficiaries and the environment The framework is intended to protect against both local impacts of individual sub-projects and the cumulative impact of many similar subprojects in the same area

13 Although many sub-projects have little or no adverse impact it is important nonetheless to acknowledge the possible unfavorable effects Experience shows that CDD projects need to establish simple social and environmental assessment procedures to avoid causing adverse harm to human health and the environment

14 The main elements of the Environmental and Social Assessment Framework (ESAF)are described below

Tools These tools usually include guidance written in the local language and presented in a form easily understood by community facilitators as well as

(i) rules-based social and environmental criteria establishing basic dorsquos and donrsquots and indicating the permissions and clearances required for common activities and(ii) mitigation guidelines providing practical guidance for the avoidance or mitigation of potential environmental impacts and identifying issues for which more specific expert guidance should be sought

Implementation Arrangements A description of roles and responsibilities to ensure that the identification avoidance and mitigation of environmental and social risks should be built into sub-project preparation appraisal and supervision This normally includes roles at the levels of community facilitators local management and program-wide management These should also be reflected in any Operational Manual that is prepared This description should abide by the rules and regulations issued by the Ministry of Environment

Capacity Building Training must be provided to ensure that every person with a role in the safeguard implementation arrangements is able to fulfill their responsibilities It is important that training in environmental and social safeguards management is incorporated from the very start of the program before the preparation of sub-projects begins

Supervision and Monitoring Arrangements should be in place to supervise both the adequacy and application of the safeguard management tools In addition it is useful to keep track of environmental concerns in program areas so that more specific mitigation measures can be

7Other options were considered at the time and are detailed in the EPP of the ESPISP II

13

designed and opportunities for enhancements can be promoted Secondary information gathering is usually sufficient for this purpose

Audit During preparation of the program it is useful to agree that an independent audit of the ESAF will be undertaken at mid-term to draw lessons and recommend improvements

15 Experience has shown the value of involving environmental organizations particularly those with advocacy expertise in the design of the Environmental and Social Assessment Frameworks and subsequently in the associated capacity building supervision and monitoring This in fact was done through the consultation process as it will be documented in later sections of this document Access to environmental expertise can be facilitated during program implementation through the identification of local professionals with an environmental background who can form a resource pool to be mobilized locally as subprojects require

16 Social funds and CDD programs also provide important opportunities to promote pro-poor reforms in environmental policies particularly those associated with access to natural resources and their management The involvement of national and local environmental specialists can play a valuable role in advancing these agendas

17 A development project mitigation measures (Annex I) encompass all actions taken to eliminate offset or reduce potentially adverse environmental impacts to acceptable levels Such measures are typically associated with the latter stages of project planning although in practice they may occur at any stage throughout the project cycle Normally potential impacts are identified early during the initiation and scoping stages of EA for a project and measures to avoid or minimize impacts are incorporated into the alternatives being considered In this respect some of the most important measures to protect the environment or local communities become integral to the project design and are never reflected within a formal environmental and social management plan (ESMP) For example the environmental and social bases for choosing a preferred location for a project will not necessarily be evident within the ESMP

18 Environmental and Social Management Plans (ESMPs) outline the mitigation monitoring and institutional measures to be taken during sub-project implementation and operation to avoid or control adverse environmental impacts and the actions needed to implement these measures They provide a crucial link between alternative mitigation measures evaluated and described within the EA report and ensuring that such measures are implemented EA reports are essentially planning documents with no legal basis In many cases mitigation measures outlined in EAs are described in illustrative terms or have neither been committed to by the borrower nor reflected in the project design In this regard the ESMP is a basis for negotiation and reaching agreement with borrowers on a sub-projectrsquos key social and environmental performance standards

19 This report aims at providing guidance in identifying environmental assessment needs for the various sub-projects that are funded under Component 2 of the SPPP and might have the potential of inflicting environmental impacts that need to be addressedFunded sub-projects fall under two categories

14

(i) Social Development (a) improving access to specialized social services to satisfy the needs of vulnerable groups at risk including the disabled children youth women and the elderly (b) enhancing environmental protection initiatives such as reforestation and soil erosion control wells and spring protection and preservation of natural sites

(ii) Income Enhancement Capacity building activities to support (a) micro and small entrepreneurs and non-governmental organizations providing credit to target beneficiary groups and (b) women youth and disabled people in order to provide them with demand driven specialized skills to improve their income and enhance their business opportunities

2 POLICY LEGAL amp INSTITUTIONAL FRAMEWORK FOR THE ENVIRONMENT

21 Regulatory Framework for Environmental Impact Assessment

20 Presently the environmental framework of Lebanon is managed and supervised by the Ministry of Environment (MOE) that was created by law 216 of April 2nd 1993 to be the government institution responsible for the development of a national strategy for sustainable development This was strengthened through the Law 4442002 Framework Law for the Protection of the Environment and the CEA (Country Environmental Analysis) The MOE is undergoing several review procedures to up-date the countryrsquos environmental policies and regulations including the preparation of an Environmental Code issuance of an Environmental Impact Assessment (EIA) decree as well as norms and standards for environmental protection The Environmental codes as well as the EIA decree were prepared with the assistance of the World Bank under the Mediterranean Environmental Technical Assistance Program (METAP) Also the World Bank has financed through METAP an assessment of the EIA System in Lebanon (Annex II)

METAP has also supported the establishment of an Environmental Management System Unit (EMSU) dealing with EIA at the MOE The concept of EA as part of project planning in Lebanon is still new and has only recently gained some attention The Environmental Impact Assessment (EIA) decree that was prepared by the MOE will require that an EIA be prepared during the planning process of both public and private development projects in Lebanon

22 Existing Environmental Legislation

221 International Conventions

21 The Lebanese Government has ratified a large number of international conventions for Environmental Protection Among the most important ones are

The Barcelona Convention for the protection of the Mediterranean SEA International Convention on World Heritage Protection International Convention on Bio-diversity Protection United Nations Convention on Desertification Montreal Protocol for the protection of the Ozone layer

15

222 Existing Lebanese Legislations

22 A list of the most significant existing environmental legislation is given in Annex II The primary safeguards as they are likely to affect SPPP subprojects are summarized in the following sections

Natural LandscapeProtection of the natural landscape of Lebanon was first addressed under the Law of January 1949 Recently cutting of trees was severely restricted under Decree No142 of March 1993 and further protection was provided under Law No 550 dated July 1996 There are also a number of Laws and Decisions that were issued to protect sites of particularly valuable landscape by declaring them Natural Reserves

Soil Water and Air PollutionProtection against pollution was first addressed by Decree No 8735 of October 1974 that prohibited the digging of wells for the disposal of raw sewage banned infiltration from cesspools and the use of sewage for the irrigation of vegetables and some fruits Decision No 521 of July 1996 introduced measures to deal with the pollution of the air water and soil including national standards for drinking water bathing waters and wastewater quality Recently Decision No 81 dated March 2001completed and reviewed the previously issued standards

Water ResourcesGround and surface water resources have been protected since the introduction of Order No 144 dated June 1925 which covered the major springs that supply the countryrsquos potable and irrigation needs Zoning of water sources and recharging of catchment areas was introduced by Decree 10276 of October 1962 to cope with increasing demand for water In 1970 Decree 14438 established a limit on the depth and exploitation of unlicensed wells and boreholes 150 m and 100 m3d respectively

Archaeological and Historical SitesThe protection of archaeological and historic sites was first addressed in Law No 1666 of November 1933 Later legislation has been introduced to afford special protection to the Cultural Heritage World Heritage and Cultural Landscape Sites declared by UNESCO

Public StreetsLaw No 60 of September 1983 covers Work in public streets law No 98 of September 1989 and by Circular 695 issued by the Prime Ministerrsquos Office on March 1995

Decree 86332012 on EIA describes clearly the various measures that need to be considered in the preliminary Environmental Evaluation of any project Projects found to require further investigation will have to be subjected to an EIA whereby complete set of information is required to allow for the Ministry to suggest needed mitigation measures and issue accordingly needed permits The stipulations of the decree go in hand with most of the WB guidelines The decree describes the various categories of sub-projects that do

16

require EIA and what are the projects that might cause risks and hazards A copy of the decree will be attached as an Annex to this document

23 Permit Procedures

23 Depending on the type and size of the sub-project to be executed and according to the Lebanese legislation a number of approvals and permits might be required from various governmental agencies In view of their nature and scale the majority of the sub-projects that would be funded by the SPPP will only require the approval of the municipality and or the Ministry of Municipalities and Rural Affairs

3 POTENTIAL SIGNIFICANT ENVIRONMENTAL IMPACTS AND GOOD PRACTICE MITIGATION PROCEDURES

31 Positive Environnemental Impact

24 Most sub-projects financed by the SPPP that are well designed and properly implemented can have a positive impact on the environment The benefits of this type of sub-projects are often long term rather than short term and are not limited to the specific local community Examples of environmentally beneficial sub-projects that will be financed by the SPPP are subject to case by case assessment soil erosion protection protection of natural and cultural heritage sites

a Consultation and Public Disclosure

25 A simple approach is proposed for public consultation in the early stages of sub-project preparation and planning

The stakeholders should be made aware of the different elements and features of each sub-project and their main objectives and target groups Once an ESIA has been made the results of this study should be disclosed to all concerned primary stakeholders

The stakeholders should then be encouraged to share their concerns worries and any comments they have on the sub-project or its likely impacts This should include discussions on alternative and proposed mitigation measures that are to be accounted for in the sub-project design implementation and operation phases

The final step is to incorporate the stakeholder inputs into the sub-project plans in order to improve the sub-project design

26 The process of stakeholder involvement and consultation will continue during sub-project implementation as well in order to integrate any additional comments and worries that may arise from the construction and implementation phase

27 Consultation with the stakeholders may take different forms depending on the need and subject matter that is being communicated An informative method would be through the use of one-way communication techniques such as audio (radio) visual (television) printed (leaflets brochures pictures diagrams posters) or electronic media (internet and electronic mail) In this case the stakeholders will be merely informed with certain information and there shall be no opportunity for questions or comments In order to have interactive consultation with the

17

stakeholders two-way participatory techniques are required This may include one-to-one briefings small group and village meetings and the organization of workshops and forums

28 The technique used for the disclosure and dissemination of information and data should take into consideration stakeholder preferences and characteristics The disclosed information should be in a language that all stakeholders are familiar with and for those who are illiterate certain measures may need to be taken to ensure that they are fully aware of the contents of the disclosed documents Another important consideration is that ample time should be given to the stakeholders to review the disclosed information prior to the consultation process to allow them to thoroughly address the sub-projects various issues

29 The SPPP will also generate environmental benefits through a variety of other mechanisms among which are

(a)- Generation of environmental assessment guidelines that can be used by other organizations or ministries or could be adopted by the Ministry of Environment for more general use

(b)- Training of environmental specialists thus increasing the number of environmental professionals in the country

(c)- Improved environmental awareness in the local communities

b Future capacity building initiatives

30 These could be done through a structured training along two parallel lines (i) at the level of the implementing agencies when these are guided one by one through the process by the environmental specialist to help them look at the needed assessment and the mitigation measures if any (ii) at the level of the community by organizing awareness campaigns targeted to LCP and other prominent figures and other interested CSOs on environmental issues of relevance and how that affects the sub-projects implemented in their areas That creates a social accountability system that could be used to ensure that the sub-projects are implemented according to appropriate procedures

32 Negative Environmental Impacts

321 Overview of Negative Environmental Impacts

31 The SPPP will finance a considerable number of different types of subprojects An important percentage of the funding will be allocated for social development Though intended to improve environmental and social conditions these subprojects can have a variety of negative environmental impacts that might be encountered during the operation of the subprojects Environmental impacts arising from the operation of the different subprojects can be minimized by appropriate site selection good engineering design and appropriate construction techniques

4 IMPLEMENTATION ARRANGEMENTS

41 Environmental Guidelines

18

32 The implementation of the SPPP falls under the responsibility of MOSA who would be in charge of coordinating the various activities through its Social Development Centers (SDCs) with concerned local governments and NGOs A Project Coordination Team (PCT) will be established and would comprise experts with relevant experience in implementing similar projects and with proven capacity to handle all functions required in such a project Among its mandates the PCT will ensure that any sponsored subproject is environmentally sound and sustainable

33 The PCT shall ensure the following

Environmental considerations will be included as criteria for selecting activities to be supported by the project environmental assessment would become an integral part of the project cycle of any subproject

Environmental guidelines are followed and used throughout the project cycle

Environmental issues are introduced to beneficiaries through education and promotion of environmentally beneficial subprojects

34 The execution of the CSD will be undertaken by Civil Society Organizations (CSO) who would consist of qualified local authorities or national NGOs with strong community ties and proven execution capacity The SDC would assist local NGOs LCF and communities in identifying local needs preparing subprojects coordinating with concerned ministries and implementing the subprojects

42 Environmental Assessment (EA)

35 The World Bank Operational Policy (OP 401) on Environmental Assessment (January 1999) defines the Bankrsquos environmental assessment requirements to ensure that funded sub-projects are environmentally sound and sustainable A screening process is undertaken for all funded sub-projects to assess the magnitude and adversity of predicted environmental impacts and to determine the appropriate extent and type of EA Depending on the type location sensitivity and scale of the project as well as the nature and magnitude of environmental impacts sub-projects are classified into one of three categories

(a)- Category A Sub-Projects that are likely to cause significant and possibly irremediable environmental impacts

(b)- Category B Sub-Projects that might cause lesser adverse impacts than those of Category A and the impacts are often remediable or could be mitigated for

(c)- Category C Sub-Projects which could have minimal or no adverse environmental impacts

19

36 The SPPP will only fund sub-projects that can be classified as either Category B or Category C only For instance all income enhancement sub-projects will be classified as Category C while most social sub-projects will be Category B Sub-projects that are likely to cause substantial negative impacts and are expected to fall in Category A will not be approved for funding

37 This document will provide guidance with respect to the preparation of environmental assessment for the various funded subprojects These guidelines are based on the World Bank Operational Policies (OP 401) the Environmental Assessment Source book (1991) and its updates in addition to the Decree 86332012 on EA issued by the GOL

5 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

51 Objectives and Structure of the ESMP

38 The objectives of the ESMP are to mitigate the adverse environmental impacts identified in the SPPP The ESMP will consist of three kinds of activities

o Implementation of mitigation measures o Strengthening the capacities of PCT SDCs and local NGOs o Monitoring and evaluation of mitigation measures identified during subproject

formulation or within the environmental assessment report

52 Implementation of Mitigation Measures

39 Mitigation measures identified (Table 1) are for typical sub-projects and MOSAPCT will ensure that such measures are adhered to during the overall implementation of the SPPP

Table 1 Potential Environmental Impacts and Proposed Mitigation Measures for Different Subprojects

Project Component

Potential Impacts Mitigation Measures Responsibility

Roads rehabilitation

Clogging of natural drainage channelsEncroachment on private property

Dumping of construction wastes and accidental spills of machine fuels etcRisk of damage to unknown archaeological sites

Maintain ditches

Detailed property boundary surveys and flagging in fieldProper disposal of construction wastes

Use ldquochance findrdquo procedures and coordinate with appropriate

Contractor

ContractorIA

Contractor

IAsArcheology department

20

government agency

Rehabilitation of schools

Rehabilitation of health clinics

Irrigation and drainage

Improper disposal of wastes

Water quality degradation in ponds and reservoirsClogging of canals from weedssedimentsInefficient water flow because of heavy sedimentation

Degradation of water systems receiving irrigation waters by nutrients agrochemical and salts

Proper disposal of solid wastesPriority given to rehabilitation of toiletsInstallation of sanitation (cesspools)

Containerize infectious wastesPublic health awareness

Monitoring of water qualityOperation amp maintenance planProper design of canals and provision of access for weed and sediments removal

Control of agrochemical use

IAsMunicipality

IAscommunity

IAscommunity

Ministry of Health

Ministry of Energy and Water

IAs community

ContractorIAs

Ministry of Agriculturecommunity

53 Training Program and Capacity Building

40 The MOSA lacks the capacities and the expertise to work in the field of environmental monitoring and protection Moreover it is expected that the IAs mostly CSOs and SDCs do not have the needed resources to undertake the requirements needed in terms of EAs and designing mitigation measures This would require a detailed capacity building program that targets all levels of the decision making process in the project The central team at the MOSA and the PCT need to be oriented to the general approach to environmental safeguards importance use and how that could affect the selection implementation and monitoring of Sub-projects SDFCs and IAs should be trained on

21

the technical aspects of detection and mitigation and how these could be imbedded within the process of project identification to formulation to implementation These safeguards will have to be an integral part of any sub-project proposal and consequently any detailed action plan for any specific sub-project Environmental expertise within the implementing and executing bodies will be strengthened Training programs will designed and implemented with the assistance of a local or international expert and will target levels as stated in the Table 2 page 20

41 PCT and IAs At the initiation of the CSD and prior to bidding and selection of IAs a workshop will be provided and will include an environmental session to raise environmental awareness and to clarify the specific environmental requirements related to design and implementation of the SPPP

42 Another training workshop will be provided to the PCT and selected IAs and will cover the following to IAs

EIA techniques Screening sub-projects for environmental review Use of practical formschecklists Best environmental practices in design and implementation of projects Effective implementation of mitigation measures Project supervision Monitoring and evaluation

43 Local NGOs and Contractors IAs will be required to provide workshops for local NGOs and contractors focusing on public awareness case studies of environmental issues experienced in similar projects use of environmental guidelines and implementation of mitigation measures (Table 2 Annex III)

22

Table 2 Training and Capacity Building Program for Implementing the ESAFTraining

Capacity BuildingParticipating Stakeholders

Skills acquired Scheduling Cost Source

ManagementInstitutional

1year

SPPP manager MOSA central unit Head of concerned

departments at MOSA PCT

Decision making and delegation Work procedures Environmental awareness National guidelines WB guidelines Classification and mitigation

Prior to sub-project preparation Planning phase Refresher every 3 months as we

go along the project

Undertaken by the Environmental

SpecialistMiscellaneous

7500 USD

WBMOSA

Institutional at Intermediate levels

2 training sessions of 2 days year

(for SDC and IA X5 regions)

PCT Emanating committee SDC managers IAs

Environmental and social policies

Laws and regulations GOL and WB safeguards Evaluation and selection

During sub-project preparation Planning phase Sub-project evaluation

Undertaken by the Environmental

SpecialistMiscellaneous

30000 USD

WB MOSA

Implementation1 day session X2 year X 5 regions

IAs SDC staff Beneficiaries Municipalities

Environment and social tools Screening amp monitoring

methods Sustainability of the process Practical mitigation and

safeguards

During sub-project preparation Mobilization Implementation

Undertaken by the Environmental

SpecialistMiscellaneous

50000 USD

WB MOSA

Monitoring Evaluation and

Reporting1 dayX2 year X5

regions

IAs SDC staff Beneficiaries

Municipalities

Environmental and social monitoring and compliance

Progress report preparation Monitoring and Evaluation

During sub-project preparation MobilizationImplementation

Environmental Specialist + consultant

50000 USD

WB MOSA

Total 137500 USD (includes in kind contribution from MOSA)

23

54 Environmental Monitoring

44 Environmental Monitoring will be the responsibility of the ES PCT and MOSA Central Unit with the supervision of the LCP and will include compliance monitoring during implementation and also monitoring of significant impacts during the operation of the subproject

Table 3 Typical Examples of Monitoring Plan for the Operation of Different Subprojects

Sub-project Monitoring Indicators Responsibility FrequencyRoads rehabilitation

Operating drainage channels

NGOs in close coordination with local community

Semi-annual assessment

Improvements to Water Supply and Sanitation Facilities

Irrigation and drainage

Distribution network without leaksNo leakage or overflows of manholes or drainsWater Quality Monitoring

Irrigation network without leaksDrainage channels clean and properly maintainedWater quality parameters (pH COD BOD SS)

NGOs in close coordination with local community

Ministry of Health and Ministry of Energy and Water

NGOs in close coordination with local community

Testing by Ministry of Health and Ministry of Energy and Water

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Rehabilitation of schools

Rehabilitation of health clinics

Toilet facilities clean and functioning properlyDrinking water faucets clean and safe from contamination

NGOs in close coordination with local community and appropriate municipality

Ministry of Health in close coordination with local community

Semi-annual assessment

Semi-annual assessment

23

24

45 The Environmental Specialist (ES) of the PCT will also conduct periodic monitoring by visiting the sites of the various sub-projects at least twice during the implementation period of the sub-project

46 Monitoring indicators shall be developed for both the mobilization and the operation phase of the subprojects Monitoring of activities will have to ensure that mitigation measures of operations impacts are being implemented properly while the monitoring of operation is to ensure that no unforeseen negative impacts are arising

55 Sub-project Cycle

47 Component 2 of the SPPP is the Community Social Development Program (CSD) which will be financing community-based sub-projects through grants The Program will have two windows one for social services whereas the other is for Income Generation Activities (IGA) support with the review and approval mechanisms in large part being the same for both windows While Component 3 focuses on Poverty Targeting thus the services provided will have no impact on the environment component 1 will focus on the provision of technology and training to SDCs

48 Applicants will be invited to use standard forms (available on the MOSA website and upon request from SDCs) to submit proposals to the relevant SDC in cases where the applicant is the SDC itself the application will be submitted directly to the CSD program team in Beirut

49 SDCs will immediately check all proposals for completeness and give a receipt to the applicant with a proposal number proposals found to be incomplete will be rejected with an explanation All complete proposals will be presented for discussion to the relevant Local Community Platform (LCP) or equivalent consultative body to obtain feedback on among other things the actual need (in case of social services) or likely market value (in the case of IGA) of the proposed activity the reputation of the applicant the likely sustainability of the proposed activity the preliminary classification of the project within environmental categories (the final classification will be pending on the decision of the environmental specialist within the PCT) any problematic aspect (conflict of interest etc) and the overall compliance of the proposal with the purposes of the program This feedback is not binding but will be taken into consideration when deciding whether or not to fund the proposal The CSD program team will carry out a detailed desk review of all complete proposals to assess their technical quality as well as the budget and time line suggested for the sub-project The environmental specialist member of the Project Coordinating Team (PCT) will review the proposal and prepare all needed documentation based on his classification of the sub-project

56 Screening of Sub-Projects

50 Each sub-project to be implemented by an IA will be subjected to an environmental screening Using the screening form (Form 1) environmental and social checklists for the proposed sub-projects will be screened by the environmental specialist to identify any potential adverse impacts

25

From an environmental standpoint the screening form may identify impacts form sub-projects the issue of solid waste disposal at the site of a sub-project may come out as a point to look at in terms of designing mitigation measures to avoid negative impacts The selection of adequate storage collection and proper disposal could be steps to consider carefully

57 The Environmental and Social Screening Process

51 The objectives of sub-project screening is to determine which activities are likely to have negative environmental and social impacts

571 Subproject Screening Procedures

52 The sub-projects funded under this project are generally categorized as Category B or C and screening mechanisms would ensure that any identified Category A sub-projects are not funded under the project Due to the fact that most Category B sub-projects are small-scale which do not result in adverse negative environmental impacts this will require an ESMP which has clear due diligence environmental and social procedures (including the setting out of institutional responsibilities timing and budget) for sub-projects The ESMP should take into consideration the applicable requirements under the Bankrsquos ten safeguard policies

572 Environmental Sub-Project Screening Checklistsforms

53 The Operation Manual (OM) should contain for each type of sub-project a simple environmental screening checklist (Form 1)) which poses a series of questions designed to identify risks to the environment The goal of the checklist (also called a screening or environmental data sheet) is to identify which sub-projects require more environmental information in the form of a site-specific ESMP or which can proceed without any special mitigation measures that is falling under category C

Form 1 Environmental Screening Check-list

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

9

carrying out short surveys on a regular basis (eg opinion polls) As part of the monitoring effort as well as to promote good governance this component will finance social audits Communication outreach campaigns for the NPTP and the CSD programs will also be supported

Component 2 Community Social Development Program (CSD) (US$1729 million total cost of which US$1232 million to be financed from the loan)

5 This component aims to establish a transparent accountable and efficient national CSD program that will finance community-based sub-projects through grants The CSD program is designed building on the experience of the World Bank-supported Community Development Project (2001-2008) MOSA experiences as well as lessons learnt from other CDD programs in Lebanon and around the world Grant sizes are limited to US$50000 equivalent implementation time for each sub-grant is one year and beneficiaries will be required to make contributions upfront Targeting will be done according to two criteria (a) geographic targeting to prioritize areas of greater poverty and deprivation (eg Akkar district) based on information from updated poverty estimates and studies carried out by various donors (eg the European Union) and (b) categorical targeting to prioritize vulnerable groups (eg the handicapped) based on MOSArsquos mandate The component will consist of the following two sub-components

(a) Establishment of a National Community Social Development Program in MOSA the project will finance technical assistance in the form of key experts (eg CSD program manager engineer social specialist income-generating specialist) who will manage a transparent process of calls for proposals screening and prioritization of proposals and monitoring and supervision of sub-grant implementation

(b) Funding community-driven sub-projects The project will provide grants to eligible applicants (primarily SDCs and CSO) whose projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

10

Component 3 National Poverty Targeting Program (NPTP) (US$17286 million total cost of which US$665 million to be financed from the loan)

6 This component aims to expand the coverage from approximately 100300 (expected in 2013 baseline of SPPP) to 238700 (in 2018) individual beneficiaries as well as to improve the efficiency of the NPTP To achieve this objective the project will provide technical support for the continued roll-out and institutionalization of the NPTP which was launched in 2011 under the Bank-financed Second Emergency Social Protection Implementation Support Project (ESPISP II) Presently NPTP benefits consist of waived school and hospitalization fees coverage of chronic disease medications free schoolbooks and discounts on electricity bills The cost of these benefits as well as that of the SDC social workers involved in administering the program are being borne and will continue to be borne by the Government2 To achieve its objective this component will consist of the following three sub-components

(a) Continued roll-out and institutionalization The project will finance technical assistance for (i) supporting the program management team (ii) refining the program application forms and Proxy-Mean Testing (PMT) questionnaire (iii) upgrading the MIS module for the NPTP and establishing an archiving system (iv) adopting measures to prevent and discourage fraud and corruption (v) refining the grievance and redress mechanism for improved efficiency and transparency

(b) Access to social safety nets The project will finance technical assistance for (i) assessing the performance of the reimbursement mechanism of the NPTP benefits and designing any improvements and (ii) designing and piloting a case management approach with NPTP beneficiary households

(c) Enabling evidence-based policy making for poverty reduction The project will finance (i) technical assistance to support the Inter-ministerial Committee for Social Policy (Social-IMC) and its Secretariat (ii) technical assistance to establish a Poverty Analysis Team whose role will be to assess the poverty and inequality situation in Lebanon using Household Budget Survey (HBS) data and (iii) the design and implementation of the next HBS (in 2017) which will be a large-sample survey representative at the governorate (mohafazat) level

Component 4 Project Coordination Team (PCT) (US$214 million out of which US$195 from the loan)

7 The project will finance a team who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components (see Section III and Annex IV of the Project Appraisal Document) reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively

2 The Council of Ministers allocated US$28 million in 2011 to finance the benefits and approximately US$4 million for the hiring of 350 social workers

11

contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management

12 IMPLEMENTATION

a Institutional and Implementation Arrangements

8 MOSA is the project implementing agency and it will oversee the implementation of all SPPP activities A Project Coordinator will head the PCT and also be responsible for the implementation of Component 1 assisted by a Project Officer while Components 2 and 3 will each be headed by a Program Manager These positions will be financed by project funds A combination of contracted and MOSA staff will be responsible for the implementation of component activities

9 Each component will be overseen by a MOSA committee that will report to the Minister In the case of Components 2 and 3 the committee will be an ldquoEmanating Project Committeerdquo3 which will check the legal aspect of all activities financed and implemented by the component (which is considered an ldquoemanating projectrdquo) and oversee the way the funds are being spent In the case of Component 1 the committee will be a SDC Committee consisting of the SDC Director and other MOSA staff4

10 The heads of the components and the MOSA Minister (as well as the Director General if the position is filled) will form the SPPP Steering Committee which will meet periodically to review implementation progress and ensure coherence with ministry policies At the national policy level the Social Inter-Ministerial Committee (Social-IMC) with MOSA acting as its Technical Secretariat will ensure coordination of the SPPP with other social policies5 Further details are provided in Annex 3 of the Loan Agreement

11 With respect to the institutional setup of the NPTP the program has been operating under a ldquodual managementrdquo by MOSA and the Presidency of the Council of Ministers (PCM)6 This was deemed the best option at the time of appraisal of the ESPISP II project which supported the

3Emanating Project Committees are established as a way to circumvent the cumbersome Lebanese bureaucracy while still providing appropriate oversight They generally comprise five or six members taken from high-ranking positions within the Ministry (eg Department Directors)4 Each SDC has its own Emanating Committee so it would not be possible to also have an Emanating Committee overseeing the component5The Social-IMC established on January 22 2007 by a decree signed by the Prime Minister and composed of the Ministers of Finance Social Affairs Health Education Labor Interior amp Municipal Affairs Economy amp Trade NSSF and the President of CDR is charged with (i) drafting a comprehensive integrated and coordinated social strategy (ii) coordinating government activities for the provisions of social services (iii) ensuring coordination of all studies surveys reports related to social affairs and ensuring availability of relevant social data and indicators (iv) overseeing the implementation of social safety net programs and (v) coordinating monitoring and evaluating development programs that are financed by local and international partners6 This dual management consists of a central management unit at the PCM and Management central unit in MOSA The former is responsible for (i) co-managing the central NPTP database (ii) validating data and cross-checking with national databases (iii) processing household data and generating scores and ranks according to the proxy-means testing (PMT) formula (iv) maintaining the PMT formula (v) analyzing national data and reporting findings to the Social Inter-Ministerial Committee (Social-IMC) (vi) monitoring the NPTP targeting and (vii) auditing data processing The central unit in MOSA (through its SDCs)is responsible for (i) co-managing the central NPTP database (ii) receiving household applications (iii) interfacing with applicants (iv) entering data (v) conducting household visits (vi) checking for data errors (vii) transmitting data to the central database of the NPTP CMU and (viii) managing the public relations campaign

12

creation of the NPTP7 The present institutional setup will be retained during the implementation of the SPPP though the GOL has started discussing the possibility of consolidating the NPTP under MOSA and institutionalizing it as an independent program with its own budgetary allocations

This document is intended to look at designing the Environmental and Social Assessment Framework (ESAF) for the sub-projects to be financed under Component 2 of the SPPP

b Purpose of the Environmental and Social Assessment Framework (ESAF)

12 The ESAF is designed to ensure protection of the health and livelihood of beneficiaries and the environment The framework is intended to protect against both local impacts of individual sub-projects and the cumulative impact of many similar subprojects in the same area

13 Although many sub-projects have little or no adverse impact it is important nonetheless to acknowledge the possible unfavorable effects Experience shows that CDD projects need to establish simple social and environmental assessment procedures to avoid causing adverse harm to human health and the environment

14 The main elements of the Environmental and Social Assessment Framework (ESAF)are described below

Tools These tools usually include guidance written in the local language and presented in a form easily understood by community facilitators as well as

(i) rules-based social and environmental criteria establishing basic dorsquos and donrsquots and indicating the permissions and clearances required for common activities and(ii) mitigation guidelines providing practical guidance for the avoidance or mitigation of potential environmental impacts and identifying issues for which more specific expert guidance should be sought

Implementation Arrangements A description of roles and responsibilities to ensure that the identification avoidance and mitigation of environmental and social risks should be built into sub-project preparation appraisal and supervision This normally includes roles at the levels of community facilitators local management and program-wide management These should also be reflected in any Operational Manual that is prepared This description should abide by the rules and regulations issued by the Ministry of Environment

Capacity Building Training must be provided to ensure that every person with a role in the safeguard implementation arrangements is able to fulfill their responsibilities It is important that training in environmental and social safeguards management is incorporated from the very start of the program before the preparation of sub-projects begins

Supervision and Monitoring Arrangements should be in place to supervise both the adequacy and application of the safeguard management tools In addition it is useful to keep track of environmental concerns in program areas so that more specific mitigation measures can be

7Other options were considered at the time and are detailed in the EPP of the ESPISP II

13

designed and opportunities for enhancements can be promoted Secondary information gathering is usually sufficient for this purpose

Audit During preparation of the program it is useful to agree that an independent audit of the ESAF will be undertaken at mid-term to draw lessons and recommend improvements

15 Experience has shown the value of involving environmental organizations particularly those with advocacy expertise in the design of the Environmental and Social Assessment Frameworks and subsequently in the associated capacity building supervision and monitoring This in fact was done through the consultation process as it will be documented in later sections of this document Access to environmental expertise can be facilitated during program implementation through the identification of local professionals with an environmental background who can form a resource pool to be mobilized locally as subprojects require

16 Social funds and CDD programs also provide important opportunities to promote pro-poor reforms in environmental policies particularly those associated with access to natural resources and their management The involvement of national and local environmental specialists can play a valuable role in advancing these agendas

17 A development project mitigation measures (Annex I) encompass all actions taken to eliminate offset or reduce potentially adverse environmental impacts to acceptable levels Such measures are typically associated with the latter stages of project planning although in practice they may occur at any stage throughout the project cycle Normally potential impacts are identified early during the initiation and scoping stages of EA for a project and measures to avoid or minimize impacts are incorporated into the alternatives being considered In this respect some of the most important measures to protect the environment or local communities become integral to the project design and are never reflected within a formal environmental and social management plan (ESMP) For example the environmental and social bases for choosing a preferred location for a project will not necessarily be evident within the ESMP

18 Environmental and Social Management Plans (ESMPs) outline the mitigation monitoring and institutional measures to be taken during sub-project implementation and operation to avoid or control adverse environmental impacts and the actions needed to implement these measures They provide a crucial link between alternative mitigation measures evaluated and described within the EA report and ensuring that such measures are implemented EA reports are essentially planning documents with no legal basis In many cases mitigation measures outlined in EAs are described in illustrative terms or have neither been committed to by the borrower nor reflected in the project design In this regard the ESMP is a basis for negotiation and reaching agreement with borrowers on a sub-projectrsquos key social and environmental performance standards

19 This report aims at providing guidance in identifying environmental assessment needs for the various sub-projects that are funded under Component 2 of the SPPP and might have the potential of inflicting environmental impacts that need to be addressedFunded sub-projects fall under two categories

14

(i) Social Development (a) improving access to specialized social services to satisfy the needs of vulnerable groups at risk including the disabled children youth women and the elderly (b) enhancing environmental protection initiatives such as reforestation and soil erosion control wells and spring protection and preservation of natural sites

(ii) Income Enhancement Capacity building activities to support (a) micro and small entrepreneurs and non-governmental organizations providing credit to target beneficiary groups and (b) women youth and disabled people in order to provide them with demand driven specialized skills to improve their income and enhance their business opportunities

2 POLICY LEGAL amp INSTITUTIONAL FRAMEWORK FOR THE ENVIRONMENT

21 Regulatory Framework for Environmental Impact Assessment

20 Presently the environmental framework of Lebanon is managed and supervised by the Ministry of Environment (MOE) that was created by law 216 of April 2nd 1993 to be the government institution responsible for the development of a national strategy for sustainable development This was strengthened through the Law 4442002 Framework Law for the Protection of the Environment and the CEA (Country Environmental Analysis) The MOE is undergoing several review procedures to up-date the countryrsquos environmental policies and regulations including the preparation of an Environmental Code issuance of an Environmental Impact Assessment (EIA) decree as well as norms and standards for environmental protection The Environmental codes as well as the EIA decree were prepared with the assistance of the World Bank under the Mediterranean Environmental Technical Assistance Program (METAP) Also the World Bank has financed through METAP an assessment of the EIA System in Lebanon (Annex II)

METAP has also supported the establishment of an Environmental Management System Unit (EMSU) dealing with EIA at the MOE The concept of EA as part of project planning in Lebanon is still new and has only recently gained some attention The Environmental Impact Assessment (EIA) decree that was prepared by the MOE will require that an EIA be prepared during the planning process of both public and private development projects in Lebanon

22 Existing Environmental Legislation

221 International Conventions

21 The Lebanese Government has ratified a large number of international conventions for Environmental Protection Among the most important ones are

The Barcelona Convention for the protection of the Mediterranean SEA International Convention on World Heritage Protection International Convention on Bio-diversity Protection United Nations Convention on Desertification Montreal Protocol for the protection of the Ozone layer

15

222 Existing Lebanese Legislations

22 A list of the most significant existing environmental legislation is given in Annex II The primary safeguards as they are likely to affect SPPP subprojects are summarized in the following sections

Natural LandscapeProtection of the natural landscape of Lebanon was first addressed under the Law of January 1949 Recently cutting of trees was severely restricted under Decree No142 of March 1993 and further protection was provided under Law No 550 dated July 1996 There are also a number of Laws and Decisions that were issued to protect sites of particularly valuable landscape by declaring them Natural Reserves

Soil Water and Air PollutionProtection against pollution was first addressed by Decree No 8735 of October 1974 that prohibited the digging of wells for the disposal of raw sewage banned infiltration from cesspools and the use of sewage for the irrigation of vegetables and some fruits Decision No 521 of July 1996 introduced measures to deal with the pollution of the air water and soil including national standards for drinking water bathing waters and wastewater quality Recently Decision No 81 dated March 2001completed and reviewed the previously issued standards

Water ResourcesGround and surface water resources have been protected since the introduction of Order No 144 dated June 1925 which covered the major springs that supply the countryrsquos potable and irrigation needs Zoning of water sources and recharging of catchment areas was introduced by Decree 10276 of October 1962 to cope with increasing demand for water In 1970 Decree 14438 established a limit on the depth and exploitation of unlicensed wells and boreholes 150 m and 100 m3d respectively

Archaeological and Historical SitesThe protection of archaeological and historic sites was first addressed in Law No 1666 of November 1933 Later legislation has been introduced to afford special protection to the Cultural Heritage World Heritage and Cultural Landscape Sites declared by UNESCO

Public StreetsLaw No 60 of September 1983 covers Work in public streets law No 98 of September 1989 and by Circular 695 issued by the Prime Ministerrsquos Office on March 1995

Decree 86332012 on EIA describes clearly the various measures that need to be considered in the preliminary Environmental Evaluation of any project Projects found to require further investigation will have to be subjected to an EIA whereby complete set of information is required to allow for the Ministry to suggest needed mitigation measures and issue accordingly needed permits The stipulations of the decree go in hand with most of the WB guidelines The decree describes the various categories of sub-projects that do

16

require EIA and what are the projects that might cause risks and hazards A copy of the decree will be attached as an Annex to this document

23 Permit Procedures

23 Depending on the type and size of the sub-project to be executed and according to the Lebanese legislation a number of approvals and permits might be required from various governmental agencies In view of their nature and scale the majority of the sub-projects that would be funded by the SPPP will only require the approval of the municipality and or the Ministry of Municipalities and Rural Affairs

3 POTENTIAL SIGNIFICANT ENVIRONMENTAL IMPACTS AND GOOD PRACTICE MITIGATION PROCEDURES

31 Positive Environnemental Impact

24 Most sub-projects financed by the SPPP that are well designed and properly implemented can have a positive impact on the environment The benefits of this type of sub-projects are often long term rather than short term and are not limited to the specific local community Examples of environmentally beneficial sub-projects that will be financed by the SPPP are subject to case by case assessment soil erosion protection protection of natural and cultural heritage sites

a Consultation and Public Disclosure

25 A simple approach is proposed for public consultation in the early stages of sub-project preparation and planning

The stakeholders should be made aware of the different elements and features of each sub-project and their main objectives and target groups Once an ESIA has been made the results of this study should be disclosed to all concerned primary stakeholders

The stakeholders should then be encouraged to share their concerns worries and any comments they have on the sub-project or its likely impacts This should include discussions on alternative and proposed mitigation measures that are to be accounted for in the sub-project design implementation and operation phases

The final step is to incorporate the stakeholder inputs into the sub-project plans in order to improve the sub-project design

26 The process of stakeholder involvement and consultation will continue during sub-project implementation as well in order to integrate any additional comments and worries that may arise from the construction and implementation phase

27 Consultation with the stakeholders may take different forms depending on the need and subject matter that is being communicated An informative method would be through the use of one-way communication techniques such as audio (radio) visual (television) printed (leaflets brochures pictures diagrams posters) or electronic media (internet and electronic mail) In this case the stakeholders will be merely informed with certain information and there shall be no opportunity for questions or comments In order to have interactive consultation with the

17

stakeholders two-way participatory techniques are required This may include one-to-one briefings small group and village meetings and the organization of workshops and forums

28 The technique used for the disclosure and dissemination of information and data should take into consideration stakeholder preferences and characteristics The disclosed information should be in a language that all stakeholders are familiar with and for those who are illiterate certain measures may need to be taken to ensure that they are fully aware of the contents of the disclosed documents Another important consideration is that ample time should be given to the stakeholders to review the disclosed information prior to the consultation process to allow them to thoroughly address the sub-projects various issues

29 The SPPP will also generate environmental benefits through a variety of other mechanisms among which are

(a)- Generation of environmental assessment guidelines that can be used by other organizations or ministries or could be adopted by the Ministry of Environment for more general use

(b)- Training of environmental specialists thus increasing the number of environmental professionals in the country

(c)- Improved environmental awareness in the local communities

b Future capacity building initiatives

30 These could be done through a structured training along two parallel lines (i) at the level of the implementing agencies when these are guided one by one through the process by the environmental specialist to help them look at the needed assessment and the mitigation measures if any (ii) at the level of the community by organizing awareness campaigns targeted to LCP and other prominent figures and other interested CSOs on environmental issues of relevance and how that affects the sub-projects implemented in their areas That creates a social accountability system that could be used to ensure that the sub-projects are implemented according to appropriate procedures

32 Negative Environmental Impacts

321 Overview of Negative Environmental Impacts

31 The SPPP will finance a considerable number of different types of subprojects An important percentage of the funding will be allocated for social development Though intended to improve environmental and social conditions these subprojects can have a variety of negative environmental impacts that might be encountered during the operation of the subprojects Environmental impacts arising from the operation of the different subprojects can be minimized by appropriate site selection good engineering design and appropriate construction techniques

4 IMPLEMENTATION ARRANGEMENTS

41 Environmental Guidelines

18

32 The implementation of the SPPP falls under the responsibility of MOSA who would be in charge of coordinating the various activities through its Social Development Centers (SDCs) with concerned local governments and NGOs A Project Coordination Team (PCT) will be established and would comprise experts with relevant experience in implementing similar projects and with proven capacity to handle all functions required in such a project Among its mandates the PCT will ensure that any sponsored subproject is environmentally sound and sustainable

33 The PCT shall ensure the following

Environmental considerations will be included as criteria for selecting activities to be supported by the project environmental assessment would become an integral part of the project cycle of any subproject

Environmental guidelines are followed and used throughout the project cycle

Environmental issues are introduced to beneficiaries through education and promotion of environmentally beneficial subprojects

34 The execution of the CSD will be undertaken by Civil Society Organizations (CSO) who would consist of qualified local authorities or national NGOs with strong community ties and proven execution capacity The SDC would assist local NGOs LCF and communities in identifying local needs preparing subprojects coordinating with concerned ministries and implementing the subprojects

42 Environmental Assessment (EA)

35 The World Bank Operational Policy (OP 401) on Environmental Assessment (January 1999) defines the Bankrsquos environmental assessment requirements to ensure that funded sub-projects are environmentally sound and sustainable A screening process is undertaken for all funded sub-projects to assess the magnitude and adversity of predicted environmental impacts and to determine the appropriate extent and type of EA Depending on the type location sensitivity and scale of the project as well as the nature and magnitude of environmental impacts sub-projects are classified into one of three categories

(a)- Category A Sub-Projects that are likely to cause significant and possibly irremediable environmental impacts

(b)- Category B Sub-Projects that might cause lesser adverse impacts than those of Category A and the impacts are often remediable or could be mitigated for

(c)- Category C Sub-Projects which could have minimal or no adverse environmental impacts

19

36 The SPPP will only fund sub-projects that can be classified as either Category B or Category C only For instance all income enhancement sub-projects will be classified as Category C while most social sub-projects will be Category B Sub-projects that are likely to cause substantial negative impacts and are expected to fall in Category A will not be approved for funding

37 This document will provide guidance with respect to the preparation of environmental assessment for the various funded subprojects These guidelines are based on the World Bank Operational Policies (OP 401) the Environmental Assessment Source book (1991) and its updates in addition to the Decree 86332012 on EA issued by the GOL

5 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

51 Objectives and Structure of the ESMP

38 The objectives of the ESMP are to mitigate the adverse environmental impacts identified in the SPPP The ESMP will consist of three kinds of activities

o Implementation of mitigation measures o Strengthening the capacities of PCT SDCs and local NGOs o Monitoring and evaluation of mitigation measures identified during subproject

formulation or within the environmental assessment report

52 Implementation of Mitigation Measures

39 Mitigation measures identified (Table 1) are for typical sub-projects and MOSAPCT will ensure that such measures are adhered to during the overall implementation of the SPPP

Table 1 Potential Environmental Impacts and Proposed Mitigation Measures for Different Subprojects

Project Component

Potential Impacts Mitigation Measures Responsibility

Roads rehabilitation

Clogging of natural drainage channelsEncroachment on private property

Dumping of construction wastes and accidental spills of machine fuels etcRisk of damage to unknown archaeological sites

Maintain ditches

Detailed property boundary surveys and flagging in fieldProper disposal of construction wastes

Use ldquochance findrdquo procedures and coordinate with appropriate

Contractor

ContractorIA

Contractor

IAsArcheology department

20

government agency

Rehabilitation of schools

Rehabilitation of health clinics

Irrigation and drainage

Improper disposal of wastes

Water quality degradation in ponds and reservoirsClogging of canals from weedssedimentsInefficient water flow because of heavy sedimentation

Degradation of water systems receiving irrigation waters by nutrients agrochemical and salts

Proper disposal of solid wastesPriority given to rehabilitation of toiletsInstallation of sanitation (cesspools)

Containerize infectious wastesPublic health awareness

Monitoring of water qualityOperation amp maintenance planProper design of canals and provision of access for weed and sediments removal

Control of agrochemical use

IAsMunicipality

IAscommunity

IAscommunity

Ministry of Health

Ministry of Energy and Water

IAs community

ContractorIAs

Ministry of Agriculturecommunity

53 Training Program and Capacity Building

40 The MOSA lacks the capacities and the expertise to work in the field of environmental monitoring and protection Moreover it is expected that the IAs mostly CSOs and SDCs do not have the needed resources to undertake the requirements needed in terms of EAs and designing mitigation measures This would require a detailed capacity building program that targets all levels of the decision making process in the project The central team at the MOSA and the PCT need to be oriented to the general approach to environmental safeguards importance use and how that could affect the selection implementation and monitoring of Sub-projects SDFCs and IAs should be trained on

21

the technical aspects of detection and mitigation and how these could be imbedded within the process of project identification to formulation to implementation These safeguards will have to be an integral part of any sub-project proposal and consequently any detailed action plan for any specific sub-project Environmental expertise within the implementing and executing bodies will be strengthened Training programs will designed and implemented with the assistance of a local or international expert and will target levels as stated in the Table 2 page 20

41 PCT and IAs At the initiation of the CSD and prior to bidding and selection of IAs a workshop will be provided and will include an environmental session to raise environmental awareness and to clarify the specific environmental requirements related to design and implementation of the SPPP

42 Another training workshop will be provided to the PCT and selected IAs and will cover the following to IAs

EIA techniques Screening sub-projects for environmental review Use of practical formschecklists Best environmental practices in design and implementation of projects Effective implementation of mitigation measures Project supervision Monitoring and evaluation

43 Local NGOs and Contractors IAs will be required to provide workshops for local NGOs and contractors focusing on public awareness case studies of environmental issues experienced in similar projects use of environmental guidelines and implementation of mitigation measures (Table 2 Annex III)

22

Table 2 Training and Capacity Building Program for Implementing the ESAFTraining

Capacity BuildingParticipating Stakeholders

Skills acquired Scheduling Cost Source

ManagementInstitutional

1year

SPPP manager MOSA central unit Head of concerned

departments at MOSA PCT

Decision making and delegation Work procedures Environmental awareness National guidelines WB guidelines Classification and mitigation

Prior to sub-project preparation Planning phase Refresher every 3 months as we

go along the project

Undertaken by the Environmental

SpecialistMiscellaneous

7500 USD

WBMOSA

Institutional at Intermediate levels

2 training sessions of 2 days year

(for SDC and IA X5 regions)

PCT Emanating committee SDC managers IAs

Environmental and social policies

Laws and regulations GOL and WB safeguards Evaluation and selection

During sub-project preparation Planning phase Sub-project evaluation

Undertaken by the Environmental

SpecialistMiscellaneous

30000 USD

WB MOSA

Implementation1 day session X2 year X 5 regions

IAs SDC staff Beneficiaries Municipalities

Environment and social tools Screening amp monitoring

methods Sustainability of the process Practical mitigation and

safeguards

During sub-project preparation Mobilization Implementation

Undertaken by the Environmental

SpecialistMiscellaneous

50000 USD

WB MOSA

Monitoring Evaluation and

Reporting1 dayX2 year X5

regions

IAs SDC staff Beneficiaries

Municipalities

Environmental and social monitoring and compliance

Progress report preparation Monitoring and Evaluation

During sub-project preparation MobilizationImplementation

Environmental Specialist + consultant

50000 USD

WB MOSA

Total 137500 USD (includes in kind contribution from MOSA)

23

54 Environmental Monitoring

44 Environmental Monitoring will be the responsibility of the ES PCT and MOSA Central Unit with the supervision of the LCP and will include compliance monitoring during implementation and also monitoring of significant impacts during the operation of the subproject

Table 3 Typical Examples of Monitoring Plan for the Operation of Different Subprojects

Sub-project Monitoring Indicators Responsibility FrequencyRoads rehabilitation

Operating drainage channels

NGOs in close coordination with local community

Semi-annual assessment

Improvements to Water Supply and Sanitation Facilities

Irrigation and drainage

Distribution network without leaksNo leakage or overflows of manholes or drainsWater Quality Monitoring

Irrigation network without leaksDrainage channels clean and properly maintainedWater quality parameters (pH COD BOD SS)

NGOs in close coordination with local community

Ministry of Health and Ministry of Energy and Water

NGOs in close coordination with local community

Testing by Ministry of Health and Ministry of Energy and Water

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Rehabilitation of schools

Rehabilitation of health clinics

Toilet facilities clean and functioning properlyDrinking water faucets clean and safe from contamination

NGOs in close coordination with local community and appropriate municipality

Ministry of Health in close coordination with local community

Semi-annual assessment

Semi-annual assessment

23

24

45 The Environmental Specialist (ES) of the PCT will also conduct periodic monitoring by visiting the sites of the various sub-projects at least twice during the implementation period of the sub-project

46 Monitoring indicators shall be developed for both the mobilization and the operation phase of the subprojects Monitoring of activities will have to ensure that mitigation measures of operations impacts are being implemented properly while the monitoring of operation is to ensure that no unforeseen negative impacts are arising

55 Sub-project Cycle

47 Component 2 of the SPPP is the Community Social Development Program (CSD) which will be financing community-based sub-projects through grants The Program will have two windows one for social services whereas the other is for Income Generation Activities (IGA) support with the review and approval mechanisms in large part being the same for both windows While Component 3 focuses on Poverty Targeting thus the services provided will have no impact on the environment component 1 will focus on the provision of technology and training to SDCs

48 Applicants will be invited to use standard forms (available on the MOSA website and upon request from SDCs) to submit proposals to the relevant SDC in cases where the applicant is the SDC itself the application will be submitted directly to the CSD program team in Beirut

49 SDCs will immediately check all proposals for completeness and give a receipt to the applicant with a proposal number proposals found to be incomplete will be rejected with an explanation All complete proposals will be presented for discussion to the relevant Local Community Platform (LCP) or equivalent consultative body to obtain feedback on among other things the actual need (in case of social services) or likely market value (in the case of IGA) of the proposed activity the reputation of the applicant the likely sustainability of the proposed activity the preliminary classification of the project within environmental categories (the final classification will be pending on the decision of the environmental specialist within the PCT) any problematic aspect (conflict of interest etc) and the overall compliance of the proposal with the purposes of the program This feedback is not binding but will be taken into consideration when deciding whether or not to fund the proposal The CSD program team will carry out a detailed desk review of all complete proposals to assess their technical quality as well as the budget and time line suggested for the sub-project The environmental specialist member of the Project Coordinating Team (PCT) will review the proposal and prepare all needed documentation based on his classification of the sub-project

56 Screening of Sub-Projects

50 Each sub-project to be implemented by an IA will be subjected to an environmental screening Using the screening form (Form 1) environmental and social checklists for the proposed sub-projects will be screened by the environmental specialist to identify any potential adverse impacts

25

From an environmental standpoint the screening form may identify impacts form sub-projects the issue of solid waste disposal at the site of a sub-project may come out as a point to look at in terms of designing mitigation measures to avoid negative impacts The selection of adequate storage collection and proper disposal could be steps to consider carefully

57 The Environmental and Social Screening Process

51 The objectives of sub-project screening is to determine which activities are likely to have negative environmental and social impacts

571 Subproject Screening Procedures

52 The sub-projects funded under this project are generally categorized as Category B or C and screening mechanisms would ensure that any identified Category A sub-projects are not funded under the project Due to the fact that most Category B sub-projects are small-scale which do not result in adverse negative environmental impacts this will require an ESMP which has clear due diligence environmental and social procedures (including the setting out of institutional responsibilities timing and budget) for sub-projects The ESMP should take into consideration the applicable requirements under the Bankrsquos ten safeguard policies

572 Environmental Sub-Project Screening Checklistsforms

53 The Operation Manual (OM) should contain for each type of sub-project a simple environmental screening checklist (Form 1)) which poses a series of questions designed to identify risks to the environment The goal of the checklist (also called a screening or environmental data sheet) is to identify which sub-projects require more environmental information in the form of a site-specific ESMP or which can proceed without any special mitigation measures that is falling under category C

Form 1 Environmental Screening Check-list

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

10

Component 3 National Poverty Targeting Program (NPTP) (US$17286 million total cost of which US$665 million to be financed from the loan)

6 This component aims to expand the coverage from approximately 100300 (expected in 2013 baseline of SPPP) to 238700 (in 2018) individual beneficiaries as well as to improve the efficiency of the NPTP To achieve this objective the project will provide technical support for the continued roll-out and institutionalization of the NPTP which was launched in 2011 under the Bank-financed Second Emergency Social Protection Implementation Support Project (ESPISP II) Presently NPTP benefits consist of waived school and hospitalization fees coverage of chronic disease medications free schoolbooks and discounts on electricity bills The cost of these benefits as well as that of the SDC social workers involved in administering the program are being borne and will continue to be borne by the Government2 To achieve its objective this component will consist of the following three sub-components

(a) Continued roll-out and institutionalization The project will finance technical assistance for (i) supporting the program management team (ii) refining the program application forms and Proxy-Mean Testing (PMT) questionnaire (iii) upgrading the MIS module for the NPTP and establishing an archiving system (iv) adopting measures to prevent and discourage fraud and corruption (v) refining the grievance and redress mechanism for improved efficiency and transparency

(b) Access to social safety nets The project will finance technical assistance for (i) assessing the performance of the reimbursement mechanism of the NPTP benefits and designing any improvements and (ii) designing and piloting a case management approach with NPTP beneficiary households

(c) Enabling evidence-based policy making for poverty reduction The project will finance (i) technical assistance to support the Inter-ministerial Committee for Social Policy (Social-IMC) and its Secretariat (ii) technical assistance to establish a Poverty Analysis Team whose role will be to assess the poverty and inequality situation in Lebanon using Household Budget Survey (HBS) data and (iii) the design and implementation of the next HBS (in 2017) which will be a large-sample survey representative at the governorate (mohafazat) level

Component 4 Project Coordination Team (PCT) (US$214 million out of which US$195 from the loan)

7 The project will finance a team who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components (see Section III and Annex IV of the Project Appraisal Document) reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively

2 The Council of Ministers allocated US$28 million in 2011 to finance the benefits and approximately US$4 million for the hiring of 350 social workers

11

contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management

12 IMPLEMENTATION

a Institutional and Implementation Arrangements

8 MOSA is the project implementing agency and it will oversee the implementation of all SPPP activities A Project Coordinator will head the PCT and also be responsible for the implementation of Component 1 assisted by a Project Officer while Components 2 and 3 will each be headed by a Program Manager These positions will be financed by project funds A combination of contracted and MOSA staff will be responsible for the implementation of component activities

9 Each component will be overseen by a MOSA committee that will report to the Minister In the case of Components 2 and 3 the committee will be an ldquoEmanating Project Committeerdquo3 which will check the legal aspect of all activities financed and implemented by the component (which is considered an ldquoemanating projectrdquo) and oversee the way the funds are being spent In the case of Component 1 the committee will be a SDC Committee consisting of the SDC Director and other MOSA staff4

10 The heads of the components and the MOSA Minister (as well as the Director General if the position is filled) will form the SPPP Steering Committee which will meet periodically to review implementation progress and ensure coherence with ministry policies At the national policy level the Social Inter-Ministerial Committee (Social-IMC) with MOSA acting as its Technical Secretariat will ensure coordination of the SPPP with other social policies5 Further details are provided in Annex 3 of the Loan Agreement

11 With respect to the institutional setup of the NPTP the program has been operating under a ldquodual managementrdquo by MOSA and the Presidency of the Council of Ministers (PCM)6 This was deemed the best option at the time of appraisal of the ESPISP II project which supported the

3Emanating Project Committees are established as a way to circumvent the cumbersome Lebanese bureaucracy while still providing appropriate oversight They generally comprise five or six members taken from high-ranking positions within the Ministry (eg Department Directors)4 Each SDC has its own Emanating Committee so it would not be possible to also have an Emanating Committee overseeing the component5The Social-IMC established on January 22 2007 by a decree signed by the Prime Minister and composed of the Ministers of Finance Social Affairs Health Education Labor Interior amp Municipal Affairs Economy amp Trade NSSF and the President of CDR is charged with (i) drafting a comprehensive integrated and coordinated social strategy (ii) coordinating government activities for the provisions of social services (iii) ensuring coordination of all studies surveys reports related to social affairs and ensuring availability of relevant social data and indicators (iv) overseeing the implementation of social safety net programs and (v) coordinating monitoring and evaluating development programs that are financed by local and international partners6 This dual management consists of a central management unit at the PCM and Management central unit in MOSA The former is responsible for (i) co-managing the central NPTP database (ii) validating data and cross-checking with national databases (iii) processing household data and generating scores and ranks according to the proxy-means testing (PMT) formula (iv) maintaining the PMT formula (v) analyzing national data and reporting findings to the Social Inter-Ministerial Committee (Social-IMC) (vi) monitoring the NPTP targeting and (vii) auditing data processing The central unit in MOSA (through its SDCs)is responsible for (i) co-managing the central NPTP database (ii) receiving household applications (iii) interfacing with applicants (iv) entering data (v) conducting household visits (vi) checking for data errors (vii) transmitting data to the central database of the NPTP CMU and (viii) managing the public relations campaign

12

creation of the NPTP7 The present institutional setup will be retained during the implementation of the SPPP though the GOL has started discussing the possibility of consolidating the NPTP under MOSA and institutionalizing it as an independent program with its own budgetary allocations

This document is intended to look at designing the Environmental and Social Assessment Framework (ESAF) for the sub-projects to be financed under Component 2 of the SPPP

b Purpose of the Environmental and Social Assessment Framework (ESAF)

12 The ESAF is designed to ensure protection of the health and livelihood of beneficiaries and the environment The framework is intended to protect against both local impacts of individual sub-projects and the cumulative impact of many similar subprojects in the same area

13 Although many sub-projects have little or no adverse impact it is important nonetheless to acknowledge the possible unfavorable effects Experience shows that CDD projects need to establish simple social and environmental assessment procedures to avoid causing adverse harm to human health and the environment

14 The main elements of the Environmental and Social Assessment Framework (ESAF)are described below

Tools These tools usually include guidance written in the local language and presented in a form easily understood by community facilitators as well as

(i) rules-based social and environmental criteria establishing basic dorsquos and donrsquots and indicating the permissions and clearances required for common activities and(ii) mitigation guidelines providing practical guidance for the avoidance or mitigation of potential environmental impacts and identifying issues for which more specific expert guidance should be sought

Implementation Arrangements A description of roles and responsibilities to ensure that the identification avoidance and mitigation of environmental and social risks should be built into sub-project preparation appraisal and supervision This normally includes roles at the levels of community facilitators local management and program-wide management These should also be reflected in any Operational Manual that is prepared This description should abide by the rules and regulations issued by the Ministry of Environment

Capacity Building Training must be provided to ensure that every person with a role in the safeguard implementation arrangements is able to fulfill their responsibilities It is important that training in environmental and social safeguards management is incorporated from the very start of the program before the preparation of sub-projects begins

Supervision and Monitoring Arrangements should be in place to supervise both the adequacy and application of the safeguard management tools In addition it is useful to keep track of environmental concerns in program areas so that more specific mitigation measures can be

7Other options were considered at the time and are detailed in the EPP of the ESPISP II

13

designed and opportunities for enhancements can be promoted Secondary information gathering is usually sufficient for this purpose

Audit During preparation of the program it is useful to agree that an independent audit of the ESAF will be undertaken at mid-term to draw lessons and recommend improvements

15 Experience has shown the value of involving environmental organizations particularly those with advocacy expertise in the design of the Environmental and Social Assessment Frameworks and subsequently in the associated capacity building supervision and monitoring This in fact was done through the consultation process as it will be documented in later sections of this document Access to environmental expertise can be facilitated during program implementation through the identification of local professionals with an environmental background who can form a resource pool to be mobilized locally as subprojects require

16 Social funds and CDD programs also provide important opportunities to promote pro-poor reforms in environmental policies particularly those associated with access to natural resources and their management The involvement of national and local environmental specialists can play a valuable role in advancing these agendas

17 A development project mitigation measures (Annex I) encompass all actions taken to eliminate offset or reduce potentially adverse environmental impacts to acceptable levels Such measures are typically associated with the latter stages of project planning although in practice they may occur at any stage throughout the project cycle Normally potential impacts are identified early during the initiation and scoping stages of EA for a project and measures to avoid or minimize impacts are incorporated into the alternatives being considered In this respect some of the most important measures to protect the environment or local communities become integral to the project design and are never reflected within a formal environmental and social management plan (ESMP) For example the environmental and social bases for choosing a preferred location for a project will not necessarily be evident within the ESMP

18 Environmental and Social Management Plans (ESMPs) outline the mitigation monitoring and institutional measures to be taken during sub-project implementation and operation to avoid or control adverse environmental impacts and the actions needed to implement these measures They provide a crucial link between alternative mitigation measures evaluated and described within the EA report and ensuring that such measures are implemented EA reports are essentially planning documents with no legal basis In many cases mitigation measures outlined in EAs are described in illustrative terms or have neither been committed to by the borrower nor reflected in the project design In this regard the ESMP is a basis for negotiation and reaching agreement with borrowers on a sub-projectrsquos key social and environmental performance standards

19 This report aims at providing guidance in identifying environmental assessment needs for the various sub-projects that are funded under Component 2 of the SPPP and might have the potential of inflicting environmental impacts that need to be addressedFunded sub-projects fall under two categories

14

(i) Social Development (a) improving access to specialized social services to satisfy the needs of vulnerable groups at risk including the disabled children youth women and the elderly (b) enhancing environmental protection initiatives such as reforestation and soil erosion control wells and spring protection and preservation of natural sites

(ii) Income Enhancement Capacity building activities to support (a) micro and small entrepreneurs and non-governmental organizations providing credit to target beneficiary groups and (b) women youth and disabled people in order to provide them with demand driven specialized skills to improve their income and enhance their business opportunities

2 POLICY LEGAL amp INSTITUTIONAL FRAMEWORK FOR THE ENVIRONMENT

21 Regulatory Framework for Environmental Impact Assessment

20 Presently the environmental framework of Lebanon is managed and supervised by the Ministry of Environment (MOE) that was created by law 216 of April 2nd 1993 to be the government institution responsible for the development of a national strategy for sustainable development This was strengthened through the Law 4442002 Framework Law for the Protection of the Environment and the CEA (Country Environmental Analysis) The MOE is undergoing several review procedures to up-date the countryrsquos environmental policies and regulations including the preparation of an Environmental Code issuance of an Environmental Impact Assessment (EIA) decree as well as norms and standards for environmental protection The Environmental codes as well as the EIA decree were prepared with the assistance of the World Bank under the Mediterranean Environmental Technical Assistance Program (METAP) Also the World Bank has financed through METAP an assessment of the EIA System in Lebanon (Annex II)

METAP has also supported the establishment of an Environmental Management System Unit (EMSU) dealing with EIA at the MOE The concept of EA as part of project planning in Lebanon is still new and has only recently gained some attention The Environmental Impact Assessment (EIA) decree that was prepared by the MOE will require that an EIA be prepared during the planning process of both public and private development projects in Lebanon

22 Existing Environmental Legislation

221 International Conventions

21 The Lebanese Government has ratified a large number of international conventions for Environmental Protection Among the most important ones are

The Barcelona Convention for the protection of the Mediterranean SEA International Convention on World Heritage Protection International Convention on Bio-diversity Protection United Nations Convention on Desertification Montreal Protocol for the protection of the Ozone layer

15

222 Existing Lebanese Legislations

22 A list of the most significant existing environmental legislation is given in Annex II The primary safeguards as they are likely to affect SPPP subprojects are summarized in the following sections

Natural LandscapeProtection of the natural landscape of Lebanon was first addressed under the Law of January 1949 Recently cutting of trees was severely restricted under Decree No142 of March 1993 and further protection was provided under Law No 550 dated July 1996 There are also a number of Laws and Decisions that were issued to protect sites of particularly valuable landscape by declaring them Natural Reserves

Soil Water and Air PollutionProtection against pollution was first addressed by Decree No 8735 of October 1974 that prohibited the digging of wells for the disposal of raw sewage banned infiltration from cesspools and the use of sewage for the irrigation of vegetables and some fruits Decision No 521 of July 1996 introduced measures to deal with the pollution of the air water and soil including national standards for drinking water bathing waters and wastewater quality Recently Decision No 81 dated March 2001completed and reviewed the previously issued standards

Water ResourcesGround and surface water resources have been protected since the introduction of Order No 144 dated June 1925 which covered the major springs that supply the countryrsquos potable and irrigation needs Zoning of water sources and recharging of catchment areas was introduced by Decree 10276 of October 1962 to cope with increasing demand for water In 1970 Decree 14438 established a limit on the depth and exploitation of unlicensed wells and boreholes 150 m and 100 m3d respectively

Archaeological and Historical SitesThe protection of archaeological and historic sites was first addressed in Law No 1666 of November 1933 Later legislation has been introduced to afford special protection to the Cultural Heritage World Heritage and Cultural Landscape Sites declared by UNESCO

Public StreetsLaw No 60 of September 1983 covers Work in public streets law No 98 of September 1989 and by Circular 695 issued by the Prime Ministerrsquos Office on March 1995

Decree 86332012 on EIA describes clearly the various measures that need to be considered in the preliminary Environmental Evaluation of any project Projects found to require further investigation will have to be subjected to an EIA whereby complete set of information is required to allow for the Ministry to suggest needed mitigation measures and issue accordingly needed permits The stipulations of the decree go in hand with most of the WB guidelines The decree describes the various categories of sub-projects that do

16

require EIA and what are the projects that might cause risks and hazards A copy of the decree will be attached as an Annex to this document

23 Permit Procedures

23 Depending on the type and size of the sub-project to be executed and according to the Lebanese legislation a number of approvals and permits might be required from various governmental agencies In view of their nature and scale the majority of the sub-projects that would be funded by the SPPP will only require the approval of the municipality and or the Ministry of Municipalities and Rural Affairs

3 POTENTIAL SIGNIFICANT ENVIRONMENTAL IMPACTS AND GOOD PRACTICE MITIGATION PROCEDURES

31 Positive Environnemental Impact

24 Most sub-projects financed by the SPPP that are well designed and properly implemented can have a positive impact on the environment The benefits of this type of sub-projects are often long term rather than short term and are not limited to the specific local community Examples of environmentally beneficial sub-projects that will be financed by the SPPP are subject to case by case assessment soil erosion protection protection of natural and cultural heritage sites

a Consultation and Public Disclosure

25 A simple approach is proposed for public consultation in the early stages of sub-project preparation and planning

The stakeholders should be made aware of the different elements and features of each sub-project and their main objectives and target groups Once an ESIA has been made the results of this study should be disclosed to all concerned primary stakeholders

The stakeholders should then be encouraged to share their concerns worries and any comments they have on the sub-project or its likely impacts This should include discussions on alternative and proposed mitigation measures that are to be accounted for in the sub-project design implementation and operation phases

The final step is to incorporate the stakeholder inputs into the sub-project plans in order to improve the sub-project design

26 The process of stakeholder involvement and consultation will continue during sub-project implementation as well in order to integrate any additional comments and worries that may arise from the construction and implementation phase

27 Consultation with the stakeholders may take different forms depending on the need and subject matter that is being communicated An informative method would be through the use of one-way communication techniques such as audio (radio) visual (television) printed (leaflets brochures pictures diagrams posters) or electronic media (internet and electronic mail) In this case the stakeholders will be merely informed with certain information and there shall be no opportunity for questions or comments In order to have interactive consultation with the

17

stakeholders two-way participatory techniques are required This may include one-to-one briefings small group and village meetings and the organization of workshops and forums

28 The technique used for the disclosure and dissemination of information and data should take into consideration stakeholder preferences and characteristics The disclosed information should be in a language that all stakeholders are familiar with and for those who are illiterate certain measures may need to be taken to ensure that they are fully aware of the contents of the disclosed documents Another important consideration is that ample time should be given to the stakeholders to review the disclosed information prior to the consultation process to allow them to thoroughly address the sub-projects various issues

29 The SPPP will also generate environmental benefits through a variety of other mechanisms among which are

(a)- Generation of environmental assessment guidelines that can be used by other organizations or ministries or could be adopted by the Ministry of Environment for more general use

(b)- Training of environmental specialists thus increasing the number of environmental professionals in the country

(c)- Improved environmental awareness in the local communities

b Future capacity building initiatives

30 These could be done through a structured training along two parallel lines (i) at the level of the implementing agencies when these are guided one by one through the process by the environmental specialist to help them look at the needed assessment and the mitigation measures if any (ii) at the level of the community by organizing awareness campaigns targeted to LCP and other prominent figures and other interested CSOs on environmental issues of relevance and how that affects the sub-projects implemented in their areas That creates a social accountability system that could be used to ensure that the sub-projects are implemented according to appropriate procedures

32 Negative Environmental Impacts

321 Overview of Negative Environmental Impacts

31 The SPPP will finance a considerable number of different types of subprojects An important percentage of the funding will be allocated for social development Though intended to improve environmental and social conditions these subprojects can have a variety of negative environmental impacts that might be encountered during the operation of the subprojects Environmental impacts arising from the operation of the different subprojects can be minimized by appropriate site selection good engineering design and appropriate construction techniques

4 IMPLEMENTATION ARRANGEMENTS

41 Environmental Guidelines

18

32 The implementation of the SPPP falls under the responsibility of MOSA who would be in charge of coordinating the various activities through its Social Development Centers (SDCs) with concerned local governments and NGOs A Project Coordination Team (PCT) will be established and would comprise experts with relevant experience in implementing similar projects and with proven capacity to handle all functions required in such a project Among its mandates the PCT will ensure that any sponsored subproject is environmentally sound and sustainable

33 The PCT shall ensure the following

Environmental considerations will be included as criteria for selecting activities to be supported by the project environmental assessment would become an integral part of the project cycle of any subproject

Environmental guidelines are followed and used throughout the project cycle

Environmental issues are introduced to beneficiaries through education and promotion of environmentally beneficial subprojects

34 The execution of the CSD will be undertaken by Civil Society Organizations (CSO) who would consist of qualified local authorities or national NGOs with strong community ties and proven execution capacity The SDC would assist local NGOs LCF and communities in identifying local needs preparing subprojects coordinating with concerned ministries and implementing the subprojects

42 Environmental Assessment (EA)

35 The World Bank Operational Policy (OP 401) on Environmental Assessment (January 1999) defines the Bankrsquos environmental assessment requirements to ensure that funded sub-projects are environmentally sound and sustainable A screening process is undertaken for all funded sub-projects to assess the magnitude and adversity of predicted environmental impacts and to determine the appropriate extent and type of EA Depending on the type location sensitivity and scale of the project as well as the nature and magnitude of environmental impacts sub-projects are classified into one of three categories

(a)- Category A Sub-Projects that are likely to cause significant and possibly irremediable environmental impacts

(b)- Category B Sub-Projects that might cause lesser adverse impacts than those of Category A and the impacts are often remediable or could be mitigated for

(c)- Category C Sub-Projects which could have minimal or no adverse environmental impacts

19

36 The SPPP will only fund sub-projects that can be classified as either Category B or Category C only For instance all income enhancement sub-projects will be classified as Category C while most social sub-projects will be Category B Sub-projects that are likely to cause substantial negative impacts and are expected to fall in Category A will not be approved for funding

37 This document will provide guidance with respect to the preparation of environmental assessment for the various funded subprojects These guidelines are based on the World Bank Operational Policies (OP 401) the Environmental Assessment Source book (1991) and its updates in addition to the Decree 86332012 on EA issued by the GOL

5 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

51 Objectives and Structure of the ESMP

38 The objectives of the ESMP are to mitigate the adverse environmental impacts identified in the SPPP The ESMP will consist of three kinds of activities

o Implementation of mitigation measures o Strengthening the capacities of PCT SDCs and local NGOs o Monitoring and evaluation of mitigation measures identified during subproject

formulation or within the environmental assessment report

52 Implementation of Mitigation Measures

39 Mitigation measures identified (Table 1) are for typical sub-projects and MOSAPCT will ensure that such measures are adhered to during the overall implementation of the SPPP

Table 1 Potential Environmental Impacts and Proposed Mitigation Measures for Different Subprojects

Project Component

Potential Impacts Mitigation Measures Responsibility

Roads rehabilitation

Clogging of natural drainage channelsEncroachment on private property

Dumping of construction wastes and accidental spills of machine fuels etcRisk of damage to unknown archaeological sites

Maintain ditches

Detailed property boundary surveys and flagging in fieldProper disposal of construction wastes

Use ldquochance findrdquo procedures and coordinate with appropriate

Contractor

ContractorIA

Contractor

IAsArcheology department

20

government agency

Rehabilitation of schools

Rehabilitation of health clinics

Irrigation and drainage

Improper disposal of wastes

Water quality degradation in ponds and reservoirsClogging of canals from weedssedimentsInefficient water flow because of heavy sedimentation

Degradation of water systems receiving irrigation waters by nutrients agrochemical and salts

Proper disposal of solid wastesPriority given to rehabilitation of toiletsInstallation of sanitation (cesspools)

Containerize infectious wastesPublic health awareness

Monitoring of water qualityOperation amp maintenance planProper design of canals and provision of access for weed and sediments removal

Control of agrochemical use

IAsMunicipality

IAscommunity

IAscommunity

Ministry of Health

Ministry of Energy and Water

IAs community

ContractorIAs

Ministry of Agriculturecommunity

53 Training Program and Capacity Building

40 The MOSA lacks the capacities and the expertise to work in the field of environmental monitoring and protection Moreover it is expected that the IAs mostly CSOs and SDCs do not have the needed resources to undertake the requirements needed in terms of EAs and designing mitigation measures This would require a detailed capacity building program that targets all levels of the decision making process in the project The central team at the MOSA and the PCT need to be oriented to the general approach to environmental safeguards importance use and how that could affect the selection implementation and monitoring of Sub-projects SDFCs and IAs should be trained on

21

the technical aspects of detection and mitigation and how these could be imbedded within the process of project identification to formulation to implementation These safeguards will have to be an integral part of any sub-project proposal and consequently any detailed action plan for any specific sub-project Environmental expertise within the implementing and executing bodies will be strengthened Training programs will designed and implemented with the assistance of a local or international expert and will target levels as stated in the Table 2 page 20

41 PCT and IAs At the initiation of the CSD and prior to bidding and selection of IAs a workshop will be provided and will include an environmental session to raise environmental awareness and to clarify the specific environmental requirements related to design and implementation of the SPPP

42 Another training workshop will be provided to the PCT and selected IAs and will cover the following to IAs

EIA techniques Screening sub-projects for environmental review Use of practical formschecklists Best environmental practices in design and implementation of projects Effective implementation of mitigation measures Project supervision Monitoring and evaluation

43 Local NGOs and Contractors IAs will be required to provide workshops for local NGOs and contractors focusing on public awareness case studies of environmental issues experienced in similar projects use of environmental guidelines and implementation of mitigation measures (Table 2 Annex III)

22

Table 2 Training and Capacity Building Program for Implementing the ESAFTraining

Capacity BuildingParticipating Stakeholders

Skills acquired Scheduling Cost Source

ManagementInstitutional

1year

SPPP manager MOSA central unit Head of concerned

departments at MOSA PCT

Decision making and delegation Work procedures Environmental awareness National guidelines WB guidelines Classification and mitigation

Prior to sub-project preparation Planning phase Refresher every 3 months as we

go along the project

Undertaken by the Environmental

SpecialistMiscellaneous

7500 USD

WBMOSA

Institutional at Intermediate levels

2 training sessions of 2 days year

(for SDC and IA X5 regions)

PCT Emanating committee SDC managers IAs

Environmental and social policies

Laws and regulations GOL and WB safeguards Evaluation and selection

During sub-project preparation Planning phase Sub-project evaluation

Undertaken by the Environmental

SpecialistMiscellaneous

30000 USD

WB MOSA

Implementation1 day session X2 year X 5 regions

IAs SDC staff Beneficiaries Municipalities

Environment and social tools Screening amp monitoring

methods Sustainability of the process Practical mitigation and

safeguards

During sub-project preparation Mobilization Implementation

Undertaken by the Environmental

SpecialistMiscellaneous

50000 USD

WB MOSA

Monitoring Evaluation and

Reporting1 dayX2 year X5

regions

IAs SDC staff Beneficiaries

Municipalities

Environmental and social monitoring and compliance

Progress report preparation Monitoring and Evaluation

During sub-project preparation MobilizationImplementation

Environmental Specialist + consultant

50000 USD

WB MOSA

Total 137500 USD (includes in kind contribution from MOSA)

23

54 Environmental Monitoring

44 Environmental Monitoring will be the responsibility of the ES PCT and MOSA Central Unit with the supervision of the LCP and will include compliance monitoring during implementation and also monitoring of significant impacts during the operation of the subproject

Table 3 Typical Examples of Monitoring Plan for the Operation of Different Subprojects

Sub-project Monitoring Indicators Responsibility FrequencyRoads rehabilitation

Operating drainage channels

NGOs in close coordination with local community

Semi-annual assessment

Improvements to Water Supply and Sanitation Facilities

Irrigation and drainage

Distribution network without leaksNo leakage or overflows of manholes or drainsWater Quality Monitoring

Irrigation network without leaksDrainage channels clean and properly maintainedWater quality parameters (pH COD BOD SS)

NGOs in close coordination with local community

Ministry of Health and Ministry of Energy and Water

NGOs in close coordination with local community

Testing by Ministry of Health and Ministry of Energy and Water

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Rehabilitation of schools

Rehabilitation of health clinics

Toilet facilities clean and functioning properlyDrinking water faucets clean and safe from contamination

NGOs in close coordination with local community and appropriate municipality

Ministry of Health in close coordination with local community

Semi-annual assessment

Semi-annual assessment

23

24

45 The Environmental Specialist (ES) of the PCT will also conduct periodic monitoring by visiting the sites of the various sub-projects at least twice during the implementation period of the sub-project

46 Monitoring indicators shall be developed for both the mobilization and the operation phase of the subprojects Monitoring of activities will have to ensure that mitigation measures of operations impacts are being implemented properly while the monitoring of operation is to ensure that no unforeseen negative impacts are arising

55 Sub-project Cycle

47 Component 2 of the SPPP is the Community Social Development Program (CSD) which will be financing community-based sub-projects through grants The Program will have two windows one for social services whereas the other is for Income Generation Activities (IGA) support with the review and approval mechanisms in large part being the same for both windows While Component 3 focuses on Poverty Targeting thus the services provided will have no impact on the environment component 1 will focus on the provision of technology and training to SDCs

48 Applicants will be invited to use standard forms (available on the MOSA website and upon request from SDCs) to submit proposals to the relevant SDC in cases where the applicant is the SDC itself the application will be submitted directly to the CSD program team in Beirut

49 SDCs will immediately check all proposals for completeness and give a receipt to the applicant with a proposal number proposals found to be incomplete will be rejected with an explanation All complete proposals will be presented for discussion to the relevant Local Community Platform (LCP) or equivalent consultative body to obtain feedback on among other things the actual need (in case of social services) or likely market value (in the case of IGA) of the proposed activity the reputation of the applicant the likely sustainability of the proposed activity the preliminary classification of the project within environmental categories (the final classification will be pending on the decision of the environmental specialist within the PCT) any problematic aspect (conflict of interest etc) and the overall compliance of the proposal with the purposes of the program This feedback is not binding but will be taken into consideration when deciding whether or not to fund the proposal The CSD program team will carry out a detailed desk review of all complete proposals to assess their technical quality as well as the budget and time line suggested for the sub-project The environmental specialist member of the Project Coordinating Team (PCT) will review the proposal and prepare all needed documentation based on his classification of the sub-project

56 Screening of Sub-Projects

50 Each sub-project to be implemented by an IA will be subjected to an environmental screening Using the screening form (Form 1) environmental and social checklists for the proposed sub-projects will be screened by the environmental specialist to identify any potential adverse impacts

25

From an environmental standpoint the screening form may identify impacts form sub-projects the issue of solid waste disposal at the site of a sub-project may come out as a point to look at in terms of designing mitigation measures to avoid negative impacts The selection of adequate storage collection and proper disposal could be steps to consider carefully

57 The Environmental and Social Screening Process

51 The objectives of sub-project screening is to determine which activities are likely to have negative environmental and social impacts

571 Subproject Screening Procedures

52 The sub-projects funded under this project are generally categorized as Category B or C and screening mechanisms would ensure that any identified Category A sub-projects are not funded under the project Due to the fact that most Category B sub-projects are small-scale which do not result in adverse negative environmental impacts this will require an ESMP which has clear due diligence environmental and social procedures (including the setting out of institutional responsibilities timing and budget) for sub-projects The ESMP should take into consideration the applicable requirements under the Bankrsquos ten safeguard policies

572 Environmental Sub-Project Screening Checklistsforms

53 The Operation Manual (OM) should contain for each type of sub-project a simple environmental screening checklist (Form 1)) which poses a series of questions designed to identify risks to the environment The goal of the checklist (also called a screening or environmental data sheet) is to identify which sub-projects require more environmental information in the form of a site-specific ESMP or which can proceed without any special mitigation measures that is falling under category C

Form 1 Environmental Screening Check-list

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

11

contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management

12 IMPLEMENTATION

a Institutional and Implementation Arrangements

8 MOSA is the project implementing agency and it will oversee the implementation of all SPPP activities A Project Coordinator will head the PCT and also be responsible for the implementation of Component 1 assisted by a Project Officer while Components 2 and 3 will each be headed by a Program Manager These positions will be financed by project funds A combination of contracted and MOSA staff will be responsible for the implementation of component activities

9 Each component will be overseen by a MOSA committee that will report to the Minister In the case of Components 2 and 3 the committee will be an ldquoEmanating Project Committeerdquo3 which will check the legal aspect of all activities financed and implemented by the component (which is considered an ldquoemanating projectrdquo) and oversee the way the funds are being spent In the case of Component 1 the committee will be a SDC Committee consisting of the SDC Director and other MOSA staff4

10 The heads of the components and the MOSA Minister (as well as the Director General if the position is filled) will form the SPPP Steering Committee which will meet periodically to review implementation progress and ensure coherence with ministry policies At the national policy level the Social Inter-Ministerial Committee (Social-IMC) with MOSA acting as its Technical Secretariat will ensure coordination of the SPPP with other social policies5 Further details are provided in Annex 3 of the Loan Agreement

11 With respect to the institutional setup of the NPTP the program has been operating under a ldquodual managementrdquo by MOSA and the Presidency of the Council of Ministers (PCM)6 This was deemed the best option at the time of appraisal of the ESPISP II project which supported the

3Emanating Project Committees are established as a way to circumvent the cumbersome Lebanese bureaucracy while still providing appropriate oversight They generally comprise five or six members taken from high-ranking positions within the Ministry (eg Department Directors)4 Each SDC has its own Emanating Committee so it would not be possible to also have an Emanating Committee overseeing the component5The Social-IMC established on January 22 2007 by a decree signed by the Prime Minister and composed of the Ministers of Finance Social Affairs Health Education Labor Interior amp Municipal Affairs Economy amp Trade NSSF and the President of CDR is charged with (i) drafting a comprehensive integrated and coordinated social strategy (ii) coordinating government activities for the provisions of social services (iii) ensuring coordination of all studies surveys reports related to social affairs and ensuring availability of relevant social data and indicators (iv) overseeing the implementation of social safety net programs and (v) coordinating monitoring and evaluating development programs that are financed by local and international partners6 This dual management consists of a central management unit at the PCM and Management central unit in MOSA The former is responsible for (i) co-managing the central NPTP database (ii) validating data and cross-checking with national databases (iii) processing household data and generating scores and ranks according to the proxy-means testing (PMT) formula (iv) maintaining the PMT formula (v) analyzing national data and reporting findings to the Social Inter-Ministerial Committee (Social-IMC) (vi) monitoring the NPTP targeting and (vii) auditing data processing The central unit in MOSA (through its SDCs)is responsible for (i) co-managing the central NPTP database (ii) receiving household applications (iii) interfacing with applicants (iv) entering data (v) conducting household visits (vi) checking for data errors (vii) transmitting data to the central database of the NPTP CMU and (viii) managing the public relations campaign

12

creation of the NPTP7 The present institutional setup will be retained during the implementation of the SPPP though the GOL has started discussing the possibility of consolidating the NPTP under MOSA and institutionalizing it as an independent program with its own budgetary allocations

This document is intended to look at designing the Environmental and Social Assessment Framework (ESAF) for the sub-projects to be financed under Component 2 of the SPPP

b Purpose of the Environmental and Social Assessment Framework (ESAF)

12 The ESAF is designed to ensure protection of the health and livelihood of beneficiaries and the environment The framework is intended to protect against both local impacts of individual sub-projects and the cumulative impact of many similar subprojects in the same area

13 Although many sub-projects have little or no adverse impact it is important nonetheless to acknowledge the possible unfavorable effects Experience shows that CDD projects need to establish simple social and environmental assessment procedures to avoid causing adverse harm to human health and the environment

14 The main elements of the Environmental and Social Assessment Framework (ESAF)are described below

Tools These tools usually include guidance written in the local language and presented in a form easily understood by community facilitators as well as

(i) rules-based social and environmental criteria establishing basic dorsquos and donrsquots and indicating the permissions and clearances required for common activities and(ii) mitigation guidelines providing practical guidance for the avoidance or mitigation of potential environmental impacts and identifying issues for which more specific expert guidance should be sought

Implementation Arrangements A description of roles and responsibilities to ensure that the identification avoidance and mitigation of environmental and social risks should be built into sub-project preparation appraisal and supervision This normally includes roles at the levels of community facilitators local management and program-wide management These should also be reflected in any Operational Manual that is prepared This description should abide by the rules and regulations issued by the Ministry of Environment

Capacity Building Training must be provided to ensure that every person with a role in the safeguard implementation arrangements is able to fulfill their responsibilities It is important that training in environmental and social safeguards management is incorporated from the very start of the program before the preparation of sub-projects begins

Supervision and Monitoring Arrangements should be in place to supervise both the adequacy and application of the safeguard management tools In addition it is useful to keep track of environmental concerns in program areas so that more specific mitigation measures can be

7Other options were considered at the time and are detailed in the EPP of the ESPISP II

13

designed and opportunities for enhancements can be promoted Secondary information gathering is usually sufficient for this purpose

Audit During preparation of the program it is useful to agree that an independent audit of the ESAF will be undertaken at mid-term to draw lessons and recommend improvements

15 Experience has shown the value of involving environmental organizations particularly those with advocacy expertise in the design of the Environmental and Social Assessment Frameworks and subsequently in the associated capacity building supervision and monitoring This in fact was done through the consultation process as it will be documented in later sections of this document Access to environmental expertise can be facilitated during program implementation through the identification of local professionals with an environmental background who can form a resource pool to be mobilized locally as subprojects require

16 Social funds and CDD programs also provide important opportunities to promote pro-poor reforms in environmental policies particularly those associated with access to natural resources and their management The involvement of national and local environmental specialists can play a valuable role in advancing these agendas

17 A development project mitigation measures (Annex I) encompass all actions taken to eliminate offset or reduce potentially adverse environmental impacts to acceptable levels Such measures are typically associated with the latter stages of project planning although in practice they may occur at any stage throughout the project cycle Normally potential impacts are identified early during the initiation and scoping stages of EA for a project and measures to avoid or minimize impacts are incorporated into the alternatives being considered In this respect some of the most important measures to protect the environment or local communities become integral to the project design and are never reflected within a formal environmental and social management plan (ESMP) For example the environmental and social bases for choosing a preferred location for a project will not necessarily be evident within the ESMP

18 Environmental and Social Management Plans (ESMPs) outline the mitigation monitoring and institutional measures to be taken during sub-project implementation and operation to avoid or control adverse environmental impacts and the actions needed to implement these measures They provide a crucial link between alternative mitigation measures evaluated and described within the EA report and ensuring that such measures are implemented EA reports are essentially planning documents with no legal basis In many cases mitigation measures outlined in EAs are described in illustrative terms or have neither been committed to by the borrower nor reflected in the project design In this regard the ESMP is a basis for negotiation and reaching agreement with borrowers on a sub-projectrsquos key social and environmental performance standards

19 This report aims at providing guidance in identifying environmental assessment needs for the various sub-projects that are funded under Component 2 of the SPPP and might have the potential of inflicting environmental impacts that need to be addressedFunded sub-projects fall under two categories

14

(i) Social Development (a) improving access to specialized social services to satisfy the needs of vulnerable groups at risk including the disabled children youth women and the elderly (b) enhancing environmental protection initiatives such as reforestation and soil erosion control wells and spring protection and preservation of natural sites

(ii) Income Enhancement Capacity building activities to support (a) micro and small entrepreneurs and non-governmental organizations providing credit to target beneficiary groups and (b) women youth and disabled people in order to provide them with demand driven specialized skills to improve their income and enhance their business opportunities

2 POLICY LEGAL amp INSTITUTIONAL FRAMEWORK FOR THE ENVIRONMENT

21 Regulatory Framework for Environmental Impact Assessment

20 Presently the environmental framework of Lebanon is managed and supervised by the Ministry of Environment (MOE) that was created by law 216 of April 2nd 1993 to be the government institution responsible for the development of a national strategy for sustainable development This was strengthened through the Law 4442002 Framework Law for the Protection of the Environment and the CEA (Country Environmental Analysis) The MOE is undergoing several review procedures to up-date the countryrsquos environmental policies and regulations including the preparation of an Environmental Code issuance of an Environmental Impact Assessment (EIA) decree as well as norms and standards for environmental protection The Environmental codes as well as the EIA decree were prepared with the assistance of the World Bank under the Mediterranean Environmental Technical Assistance Program (METAP) Also the World Bank has financed through METAP an assessment of the EIA System in Lebanon (Annex II)

METAP has also supported the establishment of an Environmental Management System Unit (EMSU) dealing with EIA at the MOE The concept of EA as part of project planning in Lebanon is still new and has only recently gained some attention The Environmental Impact Assessment (EIA) decree that was prepared by the MOE will require that an EIA be prepared during the planning process of both public and private development projects in Lebanon

22 Existing Environmental Legislation

221 International Conventions

21 The Lebanese Government has ratified a large number of international conventions for Environmental Protection Among the most important ones are

The Barcelona Convention for the protection of the Mediterranean SEA International Convention on World Heritage Protection International Convention on Bio-diversity Protection United Nations Convention on Desertification Montreal Protocol for the protection of the Ozone layer

15

222 Existing Lebanese Legislations

22 A list of the most significant existing environmental legislation is given in Annex II The primary safeguards as they are likely to affect SPPP subprojects are summarized in the following sections

Natural LandscapeProtection of the natural landscape of Lebanon was first addressed under the Law of January 1949 Recently cutting of trees was severely restricted under Decree No142 of March 1993 and further protection was provided under Law No 550 dated July 1996 There are also a number of Laws and Decisions that were issued to protect sites of particularly valuable landscape by declaring them Natural Reserves

Soil Water and Air PollutionProtection against pollution was first addressed by Decree No 8735 of October 1974 that prohibited the digging of wells for the disposal of raw sewage banned infiltration from cesspools and the use of sewage for the irrigation of vegetables and some fruits Decision No 521 of July 1996 introduced measures to deal with the pollution of the air water and soil including national standards for drinking water bathing waters and wastewater quality Recently Decision No 81 dated March 2001completed and reviewed the previously issued standards

Water ResourcesGround and surface water resources have been protected since the introduction of Order No 144 dated June 1925 which covered the major springs that supply the countryrsquos potable and irrigation needs Zoning of water sources and recharging of catchment areas was introduced by Decree 10276 of October 1962 to cope with increasing demand for water In 1970 Decree 14438 established a limit on the depth and exploitation of unlicensed wells and boreholes 150 m and 100 m3d respectively

Archaeological and Historical SitesThe protection of archaeological and historic sites was first addressed in Law No 1666 of November 1933 Later legislation has been introduced to afford special protection to the Cultural Heritage World Heritage and Cultural Landscape Sites declared by UNESCO

Public StreetsLaw No 60 of September 1983 covers Work in public streets law No 98 of September 1989 and by Circular 695 issued by the Prime Ministerrsquos Office on March 1995

Decree 86332012 on EIA describes clearly the various measures that need to be considered in the preliminary Environmental Evaluation of any project Projects found to require further investigation will have to be subjected to an EIA whereby complete set of information is required to allow for the Ministry to suggest needed mitigation measures and issue accordingly needed permits The stipulations of the decree go in hand with most of the WB guidelines The decree describes the various categories of sub-projects that do

16

require EIA and what are the projects that might cause risks and hazards A copy of the decree will be attached as an Annex to this document

23 Permit Procedures

23 Depending on the type and size of the sub-project to be executed and according to the Lebanese legislation a number of approvals and permits might be required from various governmental agencies In view of their nature and scale the majority of the sub-projects that would be funded by the SPPP will only require the approval of the municipality and or the Ministry of Municipalities and Rural Affairs

3 POTENTIAL SIGNIFICANT ENVIRONMENTAL IMPACTS AND GOOD PRACTICE MITIGATION PROCEDURES

31 Positive Environnemental Impact

24 Most sub-projects financed by the SPPP that are well designed and properly implemented can have a positive impact on the environment The benefits of this type of sub-projects are often long term rather than short term and are not limited to the specific local community Examples of environmentally beneficial sub-projects that will be financed by the SPPP are subject to case by case assessment soil erosion protection protection of natural and cultural heritage sites

a Consultation and Public Disclosure

25 A simple approach is proposed for public consultation in the early stages of sub-project preparation and planning

The stakeholders should be made aware of the different elements and features of each sub-project and their main objectives and target groups Once an ESIA has been made the results of this study should be disclosed to all concerned primary stakeholders

The stakeholders should then be encouraged to share their concerns worries and any comments they have on the sub-project or its likely impacts This should include discussions on alternative and proposed mitigation measures that are to be accounted for in the sub-project design implementation and operation phases

The final step is to incorporate the stakeholder inputs into the sub-project plans in order to improve the sub-project design

26 The process of stakeholder involvement and consultation will continue during sub-project implementation as well in order to integrate any additional comments and worries that may arise from the construction and implementation phase

27 Consultation with the stakeholders may take different forms depending on the need and subject matter that is being communicated An informative method would be through the use of one-way communication techniques such as audio (radio) visual (television) printed (leaflets brochures pictures diagrams posters) or electronic media (internet and electronic mail) In this case the stakeholders will be merely informed with certain information and there shall be no opportunity for questions or comments In order to have interactive consultation with the

17

stakeholders two-way participatory techniques are required This may include one-to-one briefings small group and village meetings and the organization of workshops and forums

28 The technique used for the disclosure and dissemination of information and data should take into consideration stakeholder preferences and characteristics The disclosed information should be in a language that all stakeholders are familiar with and for those who are illiterate certain measures may need to be taken to ensure that they are fully aware of the contents of the disclosed documents Another important consideration is that ample time should be given to the stakeholders to review the disclosed information prior to the consultation process to allow them to thoroughly address the sub-projects various issues

29 The SPPP will also generate environmental benefits through a variety of other mechanisms among which are

(a)- Generation of environmental assessment guidelines that can be used by other organizations or ministries or could be adopted by the Ministry of Environment for more general use

(b)- Training of environmental specialists thus increasing the number of environmental professionals in the country

(c)- Improved environmental awareness in the local communities

b Future capacity building initiatives

30 These could be done through a structured training along two parallel lines (i) at the level of the implementing agencies when these are guided one by one through the process by the environmental specialist to help them look at the needed assessment and the mitigation measures if any (ii) at the level of the community by organizing awareness campaigns targeted to LCP and other prominent figures and other interested CSOs on environmental issues of relevance and how that affects the sub-projects implemented in their areas That creates a social accountability system that could be used to ensure that the sub-projects are implemented according to appropriate procedures

32 Negative Environmental Impacts

321 Overview of Negative Environmental Impacts

31 The SPPP will finance a considerable number of different types of subprojects An important percentage of the funding will be allocated for social development Though intended to improve environmental and social conditions these subprojects can have a variety of negative environmental impacts that might be encountered during the operation of the subprojects Environmental impacts arising from the operation of the different subprojects can be minimized by appropriate site selection good engineering design and appropriate construction techniques

4 IMPLEMENTATION ARRANGEMENTS

41 Environmental Guidelines

18

32 The implementation of the SPPP falls under the responsibility of MOSA who would be in charge of coordinating the various activities through its Social Development Centers (SDCs) with concerned local governments and NGOs A Project Coordination Team (PCT) will be established and would comprise experts with relevant experience in implementing similar projects and with proven capacity to handle all functions required in such a project Among its mandates the PCT will ensure that any sponsored subproject is environmentally sound and sustainable

33 The PCT shall ensure the following

Environmental considerations will be included as criteria for selecting activities to be supported by the project environmental assessment would become an integral part of the project cycle of any subproject

Environmental guidelines are followed and used throughout the project cycle

Environmental issues are introduced to beneficiaries through education and promotion of environmentally beneficial subprojects

34 The execution of the CSD will be undertaken by Civil Society Organizations (CSO) who would consist of qualified local authorities or national NGOs with strong community ties and proven execution capacity The SDC would assist local NGOs LCF and communities in identifying local needs preparing subprojects coordinating with concerned ministries and implementing the subprojects

42 Environmental Assessment (EA)

35 The World Bank Operational Policy (OP 401) on Environmental Assessment (January 1999) defines the Bankrsquos environmental assessment requirements to ensure that funded sub-projects are environmentally sound and sustainable A screening process is undertaken for all funded sub-projects to assess the magnitude and adversity of predicted environmental impacts and to determine the appropriate extent and type of EA Depending on the type location sensitivity and scale of the project as well as the nature and magnitude of environmental impacts sub-projects are classified into one of three categories

(a)- Category A Sub-Projects that are likely to cause significant and possibly irremediable environmental impacts

(b)- Category B Sub-Projects that might cause lesser adverse impacts than those of Category A and the impacts are often remediable or could be mitigated for

(c)- Category C Sub-Projects which could have minimal or no adverse environmental impacts

19

36 The SPPP will only fund sub-projects that can be classified as either Category B or Category C only For instance all income enhancement sub-projects will be classified as Category C while most social sub-projects will be Category B Sub-projects that are likely to cause substantial negative impacts and are expected to fall in Category A will not be approved for funding

37 This document will provide guidance with respect to the preparation of environmental assessment for the various funded subprojects These guidelines are based on the World Bank Operational Policies (OP 401) the Environmental Assessment Source book (1991) and its updates in addition to the Decree 86332012 on EA issued by the GOL

5 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

51 Objectives and Structure of the ESMP

38 The objectives of the ESMP are to mitigate the adverse environmental impacts identified in the SPPP The ESMP will consist of three kinds of activities

o Implementation of mitigation measures o Strengthening the capacities of PCT SDCs and local NGOs o Monitoring and evaluation of mitigation measures identified during subproject

formulation or within the environmental assessment report

52 Implementation of Mitigation Measures

39 Mitigation measures identified (Table 1) are for typical sub-projects and MOSAPCT will ensure that such measures are adhered to during the overall implementation of the SPPP

Table 1 Potential Environmental Impacts and Proposed Mitigation Measures for Different Subprojects

Project Component

Potential Impacts Mitigation Measures Responsibility

Roads rehabilitation

Clogging of natural drainage channelsEncroachment on private property

Dumping of construction wastes and accidental spills of machine fuels etcRisk of damage to unknown archaeological sites

Maintain ditches

Detailed property boundary surveys and flagging in fieldProper disposal of construction wastes

Use ldquochance findrdquo procedures and coordinate with appropriate

Contractor

ContractorIA

Contractor

IAsArcheology department

20

government agency

Rehabilitation of schools

Rehabilitation of health clinics

Irrigation and drainage

Improper disposal of wastes

Water quality degradation in ponds and reservoirsClogging of canals from weedssedimentsInefficient water flow because of heavy sedimentation

Degradation of water systems receiving irrigation waters by nutrients agrochemical and salts

Proper disposal of solid wastesPriority given to rehabilitation of toiletsInstallation of sanitation (cesspools)

Containerize infectious wastesPublic health awareness

Monitoring of water qualityOperation amp maintenance planProper design of canals and provision of access for weed and sediments removal

Control of agrochemical use

IAsMunicipality

IAscommunity

IAscommunity

Ministry of Health

Ministry of Energy and Water

IAs community

ContractorIAs

Ministry of Agriculturecommunity

53 Training Program and Capacity Building

40 The MOSA lacks the capacities and the expertise to work in the field of environmental monitoring and protection Moreover it is expected that the IAs mostly CSOs and SDCs do not have the needed resources to undertake the requirements needed in terms of EAs and designing mitigation measures This would require a detailed capacity building program that targets all levels of the decision making process in the project The central team at the MOSA and the PCT need to be oriented to the general approach to environmental safeguards importance use and how that could affect the selection implementation and monitoring of Sub-projects SDFCs and IAs should be trained on

21

the technical aspects of detection and mitigation and how these could be imbedded within the process of project identification to formulation to implementation These safeguards will have to be an integral part of any sub-project proposal and consequently any detailed action plan for any specific sub-project Environmental expertise within the implementing and executing bodies will be strengthened Training programs will designed and implemented with the assistance of a local or international expert and will target levels as stated in the Table 2 page 20

41 PCT and IAs At the initiation of the CSD and prior to bidding and selection of IAs a workshop will be provided and will include an environmental session to raise environmental awareness and to clarify the specific environmental requirements related to design and implementation of the SPPP

42 Another training workshop will be provided to the PCT and selected IAs and will cover the following to IAs

EIA techniques Screening sub-projects for environmental review Use of practical formschecklists Best environmental practices in design and implementation of projects Effective implementation of mitigation measures Project supervision Monitoring and evaluation

43 Local NGOs and Contractors IAs will be required to provide workshops for local NGOs and contractors focusing on public awareness case studies of environmental issues experienced in similar projects use of environmental guidelines and implementation of mitigation measures (Table 2 Annex III)

22

Table 2 Training and Capacity Building Program for Implementing the ESAFTraining

Capacity BuildingParticipating Stakeholders

Skills acquired Scheduling Cost Source

ManagementInstitutional

1year

SPPP manager MOSA central unit Head of concerned

departments at MOSA PCT

Decision making and delegation Work procedures Environmental awareness National guidelines WB guidelines Classification and mitigation

Prior to sub-project preparation Planning phase Refresher every 3 months as we

go along the project

Undertaken by the Environmental

SpecialistMiscellaneous

7500 USD

WBMOSA

Institutional at Intermediate levels

2 training sessions of 2 days year

(for SDC and IA X5 regions)

PCT Emanating committee SDC managers IAs

Environmental and social policies

Laws and regulations GOL and WB safeguards Evaluation and selection

During sub-project preparation Planning phase Sub-project evaluation

Undertaken by the Environmental

SpecialistMiscellaneous

30000 USD

WB MOSA

Implementation1 day session X2 year X 5 regions

IAs SDC staff Beneficiaries Municipalities

Environment and social tools Screening amp monitoring

methods Sustainability of the process Practical mitigation and

safeguards

During sub-project preparation Mobilization Implementation

Undertaken by the Environmental

SpecialistMiscellaneous

50000 USD

WB MOSA

Monitoring Evaluation and

Reporting1 dayX2 year X5

regions

IAs SDC staff Beneficiaries

Municipalities

Environmental and social monitoring and compliance

Progress report preparation Monitoring and Evaluation

During sub-project preparation MobilizationImplementation

Environmental Specialist + consultant

50000 USD

WB MOSA

Total 137500 USD (includes in kind contribution from MOSA)

23

54 Environmental Monitoring

44 Environmental Monitoring will be the responsibility of the ES PCT and MOSA Central Unit with the supervision of the LCP and will include compliance monitoring during implementation and also monitoring of significant impacts during the operation of the subproject

Table 3 Typical Examples of Monitoring Plan for the Operation of Different Subprojects

Sub-project Monitoring Indicators Responsibility FrequencyRoads rehabilitation

Operating drainage channels

NGOs in close coordination with local community

Semi-annual assessment

Improvements to Water Supply and Sanitation Facilities

Irrigation and drainage

Distribution network without leaksNo leakage or overflows of manholes or drainsWater Quality Monitoring

Irrigation network without leaksDrainage channels clean and properly maintainedWater quality parameters (pH COD BOD SS)

NGOs in close coordination with local community

Ministry of Health and Ministry of Energy and Water

NGOs in close coordination with local community

Testing by Ministry of Health and Ministry of Energy and Water

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Rehabilitation of schools

Rehabilitation of health clinics

Toilet facilities clean and functioning properlyDrinking water faucets clean and safe from contamination

NGOs in close coordination with local community and appropriate municipality

Ministry of Health in close coordination with local community

Semi-annual assessment

Semi-annual assessment

23

24

45 The Environmental Specialist (ES) of the PCT will also conduct periodic monitoring by visiting the sites of the various sub-projects at least twice during the implementation period of the sub-project

46 Monitoring indicators shall be developed for both the mobilization and the operation phase of the subprojects Monitoring of activities will have to ensure that mitigation measures of operations impacts are being implemented properly while the monitoring of operation is to ensure that no unforeseen negative impacts are arising

55 Sub-project Cycle

47 Component 2 of the SPPP is the Community Social Development Program (CSD) which will be financing community-based sub-projects through grants The Program will have two windows one for social services whereas the other is for Income Generation Activities (IGA) support with the review and approval mechanisms in large part being the same for both windows While Component 3 focuses on Poverty Targeting thus the services provided will have no impact on the environment component 1 will focus on the provision of technology and training to SDCs

48 Applicants will be invited to use standard forms (available on the MOSA website and upon request from SDCs) to submit proposals to the relevant SDC in cases where the applicant is the SDC itself the application will be submitted directly to the CSD program team in Beirut

49 SDCs will immediately check all proposals for completeness and give a receipt to the applicant with a proposal number proposals found to be incomplete will be rejected with an explanation All complete proposals will be presented for discussion to the relevant Local Community Platform (LCP) or equivalent consultative body to obtain feedback on among other things the actual need (in case of social services) or likely market value (in the case of IGA) of the proposed activity the reputation of the applicant the likely sustainability of the proposed activity the preliminary classification of the project within environmental categories (the final classification will be pending on the decision of the environmental specialist within the PCT) any problematic aspect (conflict of interest etc) and the overall compliance of the proposal with the purposes of the program This feedback is not binding but will be taken into consideration when deciding whether or not to fund the proposal The CSD program team will carry out a detailed desk review of all complete proposals to assess their technical quality as well as the budget and time line suggested for the sub-project The environmental specialist member of the Project Coordinating Team (PCT) will review the proposal and prepare all needed documentation based on his classification of the sub-project

56 Screening of Sub-Projects

50 Each sub-project to be implemented by an IA will be subjected to an environmental screening Using the screening form (Form 1) environmental and social checklists for the proposed sub-projects will be screened by the environmental specialist to identify any potential adverse impacts

25

From an environmental standpoint the screening form may identify impacts form sub-projects the issue of solid waste disposal at the site of a sub-project may come out as a point to look at in terms of designing mitigation measures to avoid negative impacts The selection of adequate storage collection and proper disposal could be steps to consider carefully

57 The Environmental and Social Screening Process

51 The objectives of sub-project screening is to determine which activities are likely to have negative environmental and social impacts

571 Subproject Screening Procedures

52 The sub-projects funded under this project are generally categorized as Category B or C and screening mechanisms would ensure that any identified Category A sub-projects are not funded under the project Due to the fact that most Category B sub-projects are small-scale which do not result in adverse negative environmental impacts this will require an ESMP which has clear due diligence environmental and social procedures (including the setting out of institutional responsibilities timing and budget) for sub-projects The ESMP should take into consideration the applicable requirements under the Bankrsquos ten safeguard policies

572 Environmental Sub-Project Screening Checklistsforms

53 The Operation Manual (OM) should contain for each type of sub-project a simple environmental screening checklist (Form 1)) which poses a series of questions designed to identify risks to the environment The goal of the checklist (also called a screening or environmental data sheet) is to identify which sub-projects require more environmental information in the form of a site-specific ESMP or which can proceed without any special mitigation measures that is falling under category C

Form 1 Environmental Screening Check-list

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

12

creation of the NPTP7 The present institutional setup will be retained during the implementation of the SPPP though the GOL has started discussing the possibility of consolidating the NPTP under MOSA and institutionalizing it as an independent program with its own budgetary allocations

This document is intended to look at designing the Environmental and Social Assessment Framework (ESAF) for the sub-projects to be financed under Component 2 of the SPPP

b Purpose of the Environmental and Social Assessment Framework (ESAF)

12 The ESAF is designed to ensure protection of the health and livelihood of beneficiaries and the environment The framework is intended to protect against both local impacts of individual sub-projects and the cumulative impact of many similar subprojects in the same area

13 Although many sub-projects have little or no adverse impact it is important nonetheless to acknowledge the possible unfavorable effects Experience shows that CDD projects need to establish simple social and environmental assessment procedures to avoid causing adverse harm to human health and the environment

14 The main elements of the Environmental and Social Assessment Framework (ESAF)are described below

Tools These tools usually include guidance written in the local language and presented in a form easily understood by community facilitators as well as

(i) rules-based social and environmental criteria establishing basic dorsquos and donrsquots and indicating the permissions and clearances required for common activities and(ii) mitigation guidelines providing practical guidance for the avoidance or mitigation of potential environmental impacts and identifying issues for which more specific expert guidance should be sought

Implementation Arrangements A description of roles and responsibilities to ensure that the identification avoidance and mitigation of environmental and social risks should be built into sub-project preparation appraisal and supervision This normally includes roles at the levels of community facilitators local management and program-wide management These should also be reflected in any Operational Manual that is prepared This description should abide by the rules and regulations issued by the Ministry of Environment

Capacity Building Training must be provided to ensure that every person with a role in the safeguard implementation arrangements is able to fulfill their responsibilities It is important that training in environmental and social safeguards management is incorporated from the very start of the program before the preparation of sub-projects begins

Supervision and Monitoring Arrangements should be in place to supervise both the adequacy and application of the safeguard management tools In addition it is useful to keep track of environmental concerns in program areas so that more specific mitigation measures can be

7Other options were considered at the time and are detailed in the EPP of the ESPISP II

13

designed and opportunities for enhancements can be promoted Secondary information gathering is usually sufficient for this purpose

Audit During preparation of the program it is useful to agree that an independent audit of the ESAF will be undertaken at mid-term to draw lessons and recommend improvements

15 Experience has shown the value of involving environmental organizations particularly those with advocacy expertise in the design of the Environmental and Social Assessment Frameworks and subsequently in the associated capacity building supervision and monitoring This in fact was done through the consultation process as it will be documented in later sections of this document Access to environmental expertise can be facilitated during program implementation through the identification of local professionals with an environmental background who can form a resource pool to be mobilized locally as subprojects require

16 Social funds and CDD programs also provide important opportunities to promote pro-poor reforms in environmental policies particularly those associated with access to natural resources and their management The involvement of national and local environmental specialists can play a valuable role in advancing these agendas

17 A development project mitigation measures (Annex I) encompass all actions taken to eliminate offset or reduce potentially adverse environmental impacts to acceptable levels Such measures are typically associated with the latter stages of project planning although in practice they may occur at any stage throughout the project cycle Normally potential impacts are identified early during the initiation and scoping stages of EA for a project and measures to avoid or minimize impacts are incorporated into the alternatives being considered In this respect some of the most important measures to protect the environment or local communities become integral to the project design and are never reflected within a formal environmental and social management plan (ESMP) For example the environmental and social bases for choosing a preferred location for a project will not necessarily be evident within the ESMP

18 Environmental and Social Management Plans (ESMPs) outline the mitigation monitoring and institutional measures to be taken during sub-project implementation and operation to avoid or control adverse environmental impacts and the actions needed to implement these measures They provide a crucial link between alternative mitigation measures evaluated and described within the EA report and ensuring that such measures are implemented EA reports are essentially planning documents with no legal basis In many cases mitigation measures outlined in EAs are described in illustrative terms or have neither been committed to by the borrower nor reflected in the project design In this regard the ESMP is a basis for negotiation and reaching agreement with borrowers on a sub-projectrsquos key social and environmental performance standards

19 This report aims at providing guidance in identifying environmental assessment needs for the various sub-projects that are funded under Component 2 of the SPPP and might have the potential of inflicting environmental impacts that need to be addressedFunded sub-projects fall under two categories

14

(i) Social Development (a) improving access to specialized social services to satisfy the needs of vulnerable groups at risk including the disabled children youth women and the elderly (b) enhancing environmental protection initiatives such as reforestation and soil erosion control wells and spring protection and preservation of natural sites

(ii) Income Enhancement Capacity building activities to support (a) micro and small entrepreneurs and non-governmental organizations providing credit to target beneficiary groups and (b) women youth and disabled people in order to provide them with demand driven specialized skills to improve their income and enhance their business opportunities

2 POLICY LEGAL amp INSTITUTIONAL FRAMEWORK FOR THE ENVIRONMENT

21 Regulatory Framework for Environmental Impact Assessment

20 Presently the environmental framework of Lebanon is managed and supervised by the Ministry of Environment (MOE) that was created by law 216 of April 2nd 1993 to be the government institution responsible for the development of a national strategy for sustainable development This was strengthened through the Law 4442002 Framework Law for the Protection of the Environment and the CEA (Country Environmental Analysis) The MOE is undergoing several review procedures to up-date the countryrsquos environmental policies and regulations including the preparation of an Environmental Code issuance of an Environmental Impact Assessment (EIA) decree as well as norms and standards for environmental protection The Environmental codes as well as the EIA decree were prepared with the assistance of the World Bank under the Mediterranean Environmental Technical Assistance Program (METAP) Also the World Bank has financed through METAP an assessment of the EIA System in Lebanon (Annex II)

METAP has also supported the establishment of an Environmental Management System Unit (EMSU) dealing with EIA at the MOE The concept of EA as part of project planning in Lebanon is still new and has only recently gained some attention The Environmental Impact Assessment (EIA) decree that was prepared by the MOE will require that an EIA be prepared during the planning process of both public and private development projects in Lebanon

22 Existing Environmental Legislation

221 International Conventions

21 The Lebanese Government has ratified a large number of international conventions for Environmental Protection Among the most important ones are

The Barcelona Convention for the protection of the Mediterranean SEA International Convention on World Heritage Protection International Convention on Bio-diversity Protection United Nations Convention on Desertification Montreal Protocol for the protection of the Ozone layer

15

222 Existing Lebanese Legislations

22 A list of the most significant existing environmental legislation is given in Annex II The primary safeguards as they are likely to affect SPPP subprojects are summarized in the following sections

Natural LandscapeProtection of the natural landscape of Lebanon was first addressed under the Law of January 1949 Recently cutting of trees was severely restricted under Decree No142 of March 1993 and further protection was provided under Law No 550 dated July 1996 There are also a number of Laws and Decisions that were issued to protect sites of particularly valuable landscape by declaring them Natural Reserves

Soil Water and Air PollutionProtection against pollution was first addressed by Decree No 8735 of October 1974 that prohibited the digging of wells for the disposal of raw sewage banned infiltration from cesspools and the use of sewage for the irrigation of vegetables and some fruits Decision No 521 of July 1996 introduced measures to deal with the pollution of the air water and soil including national standards for drinking water bathing waters and wastewater quality Recently Decision No 81 dated March 2001completed and reviewed the previously issued standards

Water ResourcesGround and surface water resources have been protected since the introduction of Order No 144 dated June 1925 which covered the major springs that supply the countryrsquos potable and irrigation needs Zoning of water sources and recharging of catchment areas was introduced by Decree 10276 of October 1962 to cope with increasing demand for water In 1970 Decree 14438 established a limit on the depth and exploitation of unlicensed wells and boreholes 150 m and 100 m3d respectively

Archaeological and Historical SitesThe protection of archaeological and historic sites was first addressed in Law No 1666 of November 1933 Later legislation has been introduced to afford special protection to the Cultural Heritage World Heritage and Cultural Landscape Sites declared by UNESCO

Public StreetsLaw No 60 of September 1983 covers Work in public streets law No 98 of September 1989 and by Circular 695 issued by the Prime Ministerrsquos Office on March 1995

Decree 86332012 on EIA describes clearly the various measures that need to be considered in the preliminary Environmental Evaluation of any project Projects found to require further investigation will have to be subjected to an EIA whereby complete set of information is required to allow for the Ministry to suggest needed mitigation measures and issue accordingly needed permits The stipulations of the decree go in hand with most of the WB guidelines The decree describes the various categories of sub-projects that do

16

require EIA and what are the projects that might cause risks and hazards A copy of the decree will be attached as an Annex to this document

23 Permit Procedures

23 Depending on the type and size of the sub-project to be executed and according to the Lebanese legislation a number of approvals and permits might be required from various governmental agencies In view of their nature and scale the majority of the sub-projects that would be funded by the SPPP will only require the approval of the municipality and or the Ministry of Municipalities and Rural Affairs

3 POTENTIAL SIGNIFICANT ENVIRONMENTAL IMPACTS AND GOOD PRACTICE MITIGATION PROCEDURES

31 Positive Environnemental Impact

24 Most sub-projects financed by the SPPP that are well designed and properly implemented can have a positive impact on the environment The benefits of this type of sub-projects are often long term rather than short term and are not limited to the specific local community Examples of environmentally beneficial sub-projects that will be financed by the SPPP are subject to case by case assessment soil erosion protection protection of natural and cultural heritage sites

a Consultation and Public Disclosure

25 A simple approach is proposed for public consultation in the early stages of sub-project preparation and planning

The stakeholders should be made aware of the different elements and features of each sub-project and their main objectives and target groups Once an ESIA has been made the results of this study should be disclosed to all concerned primary stakeholders

The stakeholders should then be encouraged to share their concerns worries and any comments they have on the sub-project or its likely impacts This should include discussions on alternative and proposed mitigation measures that are to be accounted for in the sub-project design implementation and operation phases

The final step is to incorporate the stakeholder inputs into the sub-project plans in order to improve the sub-project design

26 The process of stakeholder involvement and consultation will continue during sub-project implementation as well in order to integrate any additional comments and worries that may arise from the construction and implementation phase

27 Consultation with the stakeholders may take different forms depending on the need and subject matter that is being communicated An informative method would be through the use of one-way communication techniques such as audio (radio) visual (television) printed (leaflets brochures pictures diagrams posters) or electronic media (internet and electronic mail) In this case the stakeholders will be merely informed with certain information and there shall be no opportunity for questions or comments In order to have interactive consultation with the

17

stakeholders two-way participatory techniques are required This may include one-to-one briefings small group and village meetings and the organization of workshops and forums

28 The technique used for the disclosure and dissemination of information and data should take into consideration stakeholder preferences and characteristics The disclosed information should be in a language that all stakeholders are familiar with and for those who are illiterate certain measures may need to be taken to ensure that they are fully aware of the contents of the disclosed documents Another important consideration is that ample time should be given to the stakeholders to review the disclosed information prior to the consultation process to allow them to thoroughly address the sub-projects various issues

29 The SPPP will also generate environmental benefits through a variety of other mechanisms among which are

(a)- Generation of environmental assessment guidelines that can be used by other organizations or ministries or could be adopted by the Ministry of Environment for more general use

(b)- Training of environmental specialists thus increasing the number of environmental professionals in the country

(c)- Improved environmental awareness in the local communities

b Future capacity building initiatives

30 These could be done through a structured training along two parallel lines (i) at the level of the implementing agencies when these are guided one by one through the process by the environmental specialist to help them look at the needed assessment and the mitigation measures if any (ii) at the level of the community by organizing awareness campaigns targeted to LCP and other prominent figures and other interested CSOs on environmental issues of relevance and how that affects the sub-projects implemented in their areas That creates a social accountability system that could be used to ensure that the sub-projects are implemented according to appropriate procedures

32 Negative Environmental Impacts

321 Overview of Negative Environmental Impacts

31 The SPPP will finance a considerable number of different types of subprojects An important percentage of the funding will be allocated for social development Though intended to improve environmental and social conditions these subprojects can have a variety of negative environmental impacts that might be encountered during the operation of the subprojects Environmental impacts arising from the operation of the different subprojects can be minimized by appropriate site selection good engineering design and appropriate construction techniques

4 IMPLEMENTATION ARRANGEMENTS

41 Environmental Guidelines

18

32 The implementation of the SPPP falls under the responsibility of MOSA who would be in charge of coordinating the various activities through its Social Development Centers (SDCs) with concerned local governments and NGOs A Project Coordination Team (PCT) will be established and would comprise experts with relevant experience in implementing similar projects and with proven capacity to handle all functions required in such a project Among its mandates the PCT will ensure that any sponsored subproject is environmentally sound and sustainable

33 The PCT shall ensure the following

Environmental considerations will be included as criteria for selecting activities to be supported by the project environmental assessment would become an integral part of the project cycle of any subproject

Environmental guidelines are followed and used throughout the project cycle

Environmental issues are introduced to beneficiaries through education and promotion of environmentally beneficial subprojects

34 The execution of the CSD will be undertaken by Civil Society Organizations (CSO) who would consist of qualified local authorities or national NGOs with strong community ties and proven execution capacity The SDC would assist local NGOs LCF and communities in identifying local needs preparing subprojects coordinating with concerned ministries and implementing the subprojects

42 Environmental Assessment (EA)

35 The World Bank Operational Policy (OP 401) on Environmental Assessment (January 1999) defines the Bankrsquos environmental assessment requirements to ensure that funded sub-projects are environmentally sound and sustainable A screening process is undertaken for all funded sub-projects to assess the magnitude and adversity of predicted environmental impacts and to determine the appropriate extent and type of EA Depending on the type location sensitivity and scale of the project as well as the nature and magnitude of environmental impacts sub-projects are classified into one of three categories

(a)- Category A Sub-Projects that are likely to cause significant and possibly irremediable environmental impacts

(b)- Category B Sub-Projects that might cause lesser adverse impacts than those of Category A and the impacts are often remediable or could be mitigated for

(c)- Category C Sub-Projects which could have minimal or no adverse environmental impacts

19

36 The SPPP will only fund sub-projects that can be classified as either Category B or Category C only For instance all income enhancement sub-projects will be classified as Category C while most social sub-projects will be Category B Sub-projects that are likely to cause substantial negative impacts and are expected to fall in Category A will not be approved for funding

37 This document will provide guidance with respect to the preparation of environmental assessment for the various funded subprojects These guidelines are based on the World Bank Operational Policies (OP 401) the Environmental Assessment Source book (1991) and its updates in addition to the Decree 86332012 on EA issued by the GOL

5 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

51 Objectives and Structure of the ESMP

38 The objectives of the ESMP are to mitigate the adverse environmental impacts identified in the SPPP The ESMP will consist of three kinds of activities

o Implementation of mitigation measures o Strengthening the capacities of PCT SDCs and local NGOs o Monitoring and evaluation of mitigation measures identified during subproject

formulation or within the environmental assessment report

52 Implementation of Mitigation Measures

39 Mitigation measures identified (Table 1) are for typical sub-projects and MOSAPCT will ensure that such measures are adhered to during the overall implementation of the SPPP

Table 1 Potential Environmental Impacts and Proposed Mitigation Measures for Different Subprojects

Project Component

Potential Impacts Mitigation Measures Responsibility

Roads rehabilitation

Clogging of natural drainage channelsEncroachment on private property

Dumping of construction wastes and accidental spills of machine fuels etcRisk of damage to unknown archaeological sites

Maintain ditches

Detailed property boundary surveys and flagging in fieldProper disposal of construction wastes

Use ldquochance findrdquo procedures and coordinate with appropriate

Contractor

ContractorIA

Contractor

IAsArcheology department

20

government agency

Rehabilitation of schools

Rehabilitation of health clinics

Irrigation and drainage

Improper disposal of wastes

Water quality degradation in ponds and reservoirsClogging of canals from weedssedimentsInefficient water flow because of heavy sedimentation

Degradation of water systems receiving irrigation waters by nutrients agrochemical and salts

Proper disposal of solid wastesPriority given to rehabilitation of toiletsInstallation of sanitation (cesspools)

Containerize infectious wastesPublic health awareness

Monitoring of water qualityOperation amp maintenance planProper design of canals and provision of access for weed and sediments removal

Control of agrochemical use

IAsMunicipality

IAscommunity

IAscommunity

Ministry of Health

Ministry of Energy and Water

IAs community

ContractorIAs

Ministry of Agriculturecommunity

53 Training Program and Capacity Building

40 The MOSA lacks the capacities and the expertise to work in the field of environmental monitoring and protection Moreover it is expected that the IAs mostly CSOs and SDCs do not have the needed resources to undertake the requirements needed in terms of EAs and designing mitigation measures This would require a detailed capacity building program that targets all levels of the decision making process in the project The central team at the MOSA and the PCT need to be oriented to the general approach to environmental safeguards importance use and how that could affect the selection implementation and monitoring of Sub-projects SDFCs and IAs should be trained on

21

the technical aspects of detection and mitigation and how these could be imbedded within the process of project identification to formulation to implementation These safeguards will have to be an integral part of any sub-project proposal and consequently any detailed action plan for any specific sub-project Environmental expertise within the implementing and executing bodies will be strengthened Training programs will designed and implemented with the assistance of a local or international expert and will target levels as stated in the Table 2 page 20

41 PCT and IAs At the initiation of the CSD and prior to bidding and selection of IAs a workshop will be provided and will include an environmental session to raise environmental awareness and to clarify the specific environmental requirements related to design and implementation of the SPPP

42 Another training workshop will be provided to the PCT and selected IAs and will cover the following to IAs

EIA techniques Screening sub-projects for environmental review Use of practical formschecklists Best environmental practices in design and implementation of projects Effective implementation of mitigation measures Project supervision Monitoring and evaluation

43 Local NGOs and Contractors IAs will be required to provide workshops for local NGOs and contractors focusing on public awareness case studies of environmental issues experienced in similar projects use of environmental guidelines and implementation of mitigation measures (Table 2 Annex III)

22

Table 2 Training and Capacity Building Program for Implementing the ESAFTraining

Capacity BuildingParticipating Stakeholders

Skills acquired Scheduling Cost Source

ManagementInstitutional

1year

SPPP manager MOSA central unit Head of concerned

departments at MOSA PCT

Decision making and delegation Work procedures Environmental awareness National guidelines WB guidelines Classification and mitigation

Prior to sub-project preparation Planning phase Refresher every 3 months as we

go along the project

Undertaken by the Environmental

SpecialistMiscellaneous

7500 USD

WBMOSA

Institutional at Intermediate levels

2 training sessions of 2 days year

(for SDC and IA X5 regions)

PCT Emanating committee SDC managers IAs

Environmental and social policies

Laws and regulations GOL and WB safeguards Evaluation and selection

During sub-project preparation Planning phase Sub-project evaluation

Undertaken by the Environmental

SpecialistMiscellaneous

30000 USD

WB MOSA

Implementation1 day session X2 year X 5 regions

IAs SDC staff Beneficiaries Municipalities

Environment and social tools Screening amp monitoring

methods Sustainability of the process Practical mitigation and

safeguards

During sub-project preparation Mobilization Implementation

Undertaken by the Environmental

SpecialistMiscellaneous

50000 USD

WB MOSA

Monitoring Evaluation and

Reporting1 dayX2 year X5

regions

IAs SDC staff Beneficiaries

Municipalities

Environmental and social monitoring and compliance

Progress report preparation Monitoring and Evaluation

During sub-project preparation MobilizationImplementation

Environmental Specialist + consultant

50000 USD

WB MOSA

Total 137500 USD (includes in kind contribution from MOSA)

23

54 Environmental Monitoring

44 Environmental Monitoring will be the responsibility of the ES PCT and MOSA Central Unit with the supervision of the LCP and will include compliance monitoring during implementation and also monitoring of significant impacts during the operation of the subproject

Table 3 Typical Examples of Monitoring Plan for the Operation of Different Subprojects

Sub-project Monitoring Indicators Responsibility FrequencyRoads rehabilitation

Operating drainage channels

NGOs in close coordination with local community

Semi-annual assessment

Improvements to Water Supply and Sanitation Facilities

Irrigation and drainage

Distribution network without leaksNo leakage or overflows of manholes or drainsWater Quality Monitoring

Irrigation network without leaksDrainage channels clean and properly maintainedWater quality parameters (pH COD BOD SS)

NGOs in close coordination with local community

Ministry of Health and Ministry of Energy and Water

NGOs in close coordination with local community

Testing by Ministry of Health and Ministry of Energy and Water

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Rehabilitation of schools

Rehabilitation of health clinics

Toilet facilities clean and functioning properlyDrinking water faucets clean and safe from contamination

NGOs in close coordination with local community and appropriate municipality

Ministry of Health in close coordination with local community

Semi-annual assessment

Semi-annual assessment

23

24

45 The Environmental Specialist (ES) of the PCT will also conduct periodic monitoring by visiting the sites of the various sub-projects at least twice during the implementation period of the sub-project

46 Monitoring indicators shall be developed for both the mobilization and the operation phase of the subprojects Monitoring of activities will have to ensure that mitigation measures of operations impacts are being implemented properly while the monitoring of operation is to ensure that no unforeseen negative impacts are arising

55 Sub-project Cycle

47 Component 2 of the SPPP is the Community Social Development Program (CSD) which will be financing community-based sub-projects through grants The Program will have two windows one for social services whereas the other is for Income Generation Activities (IGA) support with the review and approval mechanisms in large part being the same for both windows While Component 3 focuses on Poverty Targeting thus the services provided will have no impact on the environment component 1 will focus on the provision of technology and training to SDCs

48 Applicants will be invited to use standard forms (available on the MOSA website and upon request from SDCs) to submit proposals to the relevant SDC in cases where the applicant is the SDC itself the application will be submitted directly to the CSD program team in Beirut

49 SDCs will immediately check all proposals for completeness and give a receipt to the applicant with a proposal number proposals found to be incomplete will be rejected with an explanation All complete proposals will be presented for discussion to the relevant Local Community Platform (LCP) or equivalent consultative body to obtain feedback on among other things the actual need (in case of social services) or likely market value (in the case of IGA) of the proposed activity the reputation of the applicant the likely sustainability of the proposed activity the preliminary classification of the project within environmental categories (the final classification will be pending on the decision of the environmental specialist within the PCT) any problematic aspect (conflict of interest etc) and the overall compliance of the proposal with the purposes of the program This feedback is not binding but will be taken into consideration when deciding whether or not to fund the proposal The CSD program team will carry out a detailed desk review of all complete proposals to assess their technical quality as well as the budget and time line suggested for the sub-project The environmental specialist member of the Project Coordinating Team (PCT) will review the proposal and prepare all needed documentation based on his classification of the sub-project

56 Screening of Sub-Projects

50 Each sub-project to be implemented by an IA will be subjected to an environmental screening Using the screening form (Form 1) environmental and social checklists for the proposed sub-projects will be screened by the environmental specialist to identify any potential adverse impacts

25

From an environmental standpoint the screening form may identify impacts form sub-projects the issue of solid waste disposal at the site of a sub-project may come out as a point to look at in terms of designing mitigation measures to avoid negative impacts The selection of adequate storage collection and proper disposal could be steps to consider carefully

57 The Environmental and Social Screening Process

51 The objectives of sub-project screening is to determine which activities are likely to have negative environmental and social impacts

571 Subproject Screening Procedures

52 The sub-projects funded under this project are generally categorized as Category B or C and screening mechanisms would ensure that any identified Category A sub-projects are not funded under the project Due to the fact that most Category B sub-projects are small-scale which do not result in adverse negative environmental impacts this will require an ESMP which has clear due diligence environmental and social procedures (including the setting out of institutional responsibilities timing and budget) for sub-projects The ESMP should take into consideration the applicable requirements under the Bankrsquos ten safeguard policies

572 Environmental Sub-Project Screening Checklistsforms

53 The Operation Manual (OM) should contain for each type of sub-project a simple environmental screening checklist (Form 1)) which poses a series of questions designed to identify risks to the environment The goal of the checklist (also called a screening or environmental data sheet) is to identify which sub-projects require more environmental information in the form of a site-specific ESMP or which can proceed without any special mitigation measures that is falling under category C

Form 1 Environmental Screening Check-list

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

13

designed and opportunities for enhancements can be promoted Secondary information gathering is usually sufficient for this purpose

Audit During preparation of the program it is useful to agree that an independent audit of the ESAF will be undertaken at mid-term to draw lessons and recommend improvements

15 Experience has shown the value of involving environmental organizations particularly those with advocacy expertise in the design of the Environmental and Social Assessment Frameworks and subsequently in the associated capacity building supervision and monitoring This in fact was done through the consultation process as it will be documented in later sections of this document Access to environmental expertise can be facilitated during program implementation through the identification of local professionals with an environmental background who can form a resource pool to be mobilized locally as subprojects require

16 Social funds and CDD programs also provide important opportunities to promote pro-poor reforms in environmental policies particularly those associated with access to natural resources and their management The involvement of national and local environmental specialists can play a valuable role in advancing these agendas

17 A development project mitigation measures (Annex I) encompass all actions taken to eliminate offset or reduce potentially adverse environmental impacts to acceptable levels Such measures are typically associated with the latter stages of project planning although in practice they may occur at any stage throughout the project cycle Normally potential impacts are identified early during the initiation and scoping stages of EA for a project and measures to avoid or minimize impacts are incorporated into the alternatives being considered In this respect some of the most important measures to protect the environment or local communities become integral to the project design and are never reflected within a formal environmental and social management plan (ESMP) For example the environmental and social bases for choosing a preferred location for a project will not necessarily be evident within the ESMP

18 Environmental and Social Management Plans (ESMPs) outline the mitigation monitoring and institutional measures to be taken during sub-project implementation and operation to avoid or control adverse environmental impacts and the actions needed to implement these measures They provide a crucial link between alternative mitigation measures evaluated and described within the EA report and ensuring that such measures are implemented EA reports are essentially planning documents with no legal basis In many cases mitigation measures outlined in EAs are described in illustrative terms or have neither been committed to by the borrower nor reflected in the project design In this regard the ESMP is a basis for negotiation and reaching agreement with borrowers on a sub-projectrsquos key social and environmental performance standards

19 This report aims at providing guidance in identifying environmental assessment needs for the various sub-projects that are funded under Component 2 of the SPPP and might have the potential of inflicting environmental impacts that need to be addressedFunded sub-projects fall under two categories

14

(i) Social Development (a) improving access to specialized social services to satisfy the needs of vulnerable groups at risk including the disabled children youth women and the elderly (b) enhancing environmental protection initiatives such as reforestation and soil erosion control wells and spring protection and preservation of natural sites

(ii) Income Enhancement Capacity building activities to support (a) micro and small entrepreneurs and non-governmental organizations providing credit to target beneficiary groups and (b) women youth and disabled people in order to provide them with demand driven specialized skills to improve their income and enhance their business opportunities

2 POLICY LEGAL amp INSTITUTIONAL FRAMEWORK FOR THE ENVIRONMENT

21 Regulatory Framework for Environmental Impact Assessment

20 Presently the environmental framework of Lebanon is managed and supervised by the Ministry of Environment (MOE) that was created by law 216 of April 2nd 1993 to be the government institution responsible for the development of a national strategy for sustainable development This was strengthened through the Law 4442002 Framework Law for the Protection of the Environment and the CEA (Country Environmental Analysis) The MOE is undergoing several review procedures to up-date the countryrsquos environmental policies and regulations including the preparation of an Environmental Code issuance of an Environmental Impact Assessment (EIA) decree as well as norms and standards for environmental protection The Environmental codes as well as the EIA decree were prepared with the assistance of the World Bank under the Mediterranean Environmental Technical Assistance Program (METAP) Also the World Bank has financed through METAP an assessment of the EIA System in Lebanon (Annex II)

METAP has also supported the establishment of an Environmental Management System Unit (EMSU) dealing with EIA at the MOE The concept of EA as part of project planning in Lebanon is still new and has only recently gained some attention The Environmental Impact Assessment (EIA) decree that was prepared by the MOE will require that an EIA be prepared during the planning process of both public and private development projects in Lebanon

22 Existing Environmental Legislation

221 International Conventions

21 The Lebanese Government has ratified a large number of international conventions for Environmental Protection Among the most important ones are

The Barcelona Convention for the protection of the Mediterranean SEA International Convention on World Heritage Protection International Convention on Bio-diversity Protection United Nations Convention on Desertification Montreal Protocol for the protection of the Ozone layer

15

222 Existing Lebanese Legislations

22 A list of the most significant existing environmental legislation is given in Annex II The primary safeguards as they are likely to affect SPPP subprojects are summarized in the following sections

Natural LandscapeProtection of the natural landscape of Lebanon was first addressed under the Law of January 1949 Recently cutting of trees was severely restricted under Decree No142 of March 1993 and further protection was provided under Law No 550 dated July 1996 There are also a number of Laws and Decisions that were issued to protect sites of particularly valuable landscape by declaring them Natural Reserves

Soil Water and Air PollutionProtection against pollution was first addressed by Decree No 8735 of October 1974 that prohibited the digging of wells for the disposal of raw sewage banned infiltration from cesspools and the use of sewage for the irrigation of vegetables and some fruits Decision No 521 of July 1996 introduced measures to deal with the pollution of the air water and soil including national standards for drinking water bathing waters and wastewater quality Recently Decision No 81 dated March 2001completed and reviewed the previously issued standards

Water ResourcesGround and surface water resources have been protected since the introduction of Order No 144 dated June 1925 which covered the major springs that supply the countryrsquos potable and irrigation needs Zoning of water sources and recharging of catchment areas was introduced by Decree 10276 of October 1962 to cope with increasing demand for water In 1970 Decree 14438 established a limit on the depth and exploitation of unlicensed wells and boreholes 150 m and 100 m3d respectively

Archaeological and Historical SitesThe protection of archaeological and historic sites was first addressed in Law No 1666 of November 1933 Later legislation has been introduced to afford special protection to the Cultural Heritage World Heritage and Cultural Landscape Sites declared by UNESCO

Public StreetsLaw No 60 of September 1983 covers Work in public streets law No 98 of September 1989 and by Circular 695 issued by the Prime Ministerrsquos Office on March 1995

Decree 86332012 on EIA describes clearly the various measures that need to be considered in the preliminary Environmental Evaluation of any project Projects found to require further investigation will have to be subjected to an EIA whereby complete set of information is required to allow for the Ministry to suggest needed mitigation measures and issue accordingly needed permits The stipulations of the decree go in hand with most of the WB guidelines The decree describes the various categories of sub-projects that do

16

require EIA and what are the projects that might cause risks and hazards A copy of the decree will be attached as an Annex to this document

23 Permit Procedures

23 Depending on the type and size of the sub-project to be executed and according to the Lebanese legislation a number of approvals and permits might be required from various governmental agencies In view of their nature and scale the majority of the sub-projects that would be funded by the SPPP will only require the approval of the municipality and or the Ministry of Municipalities and Rural Affairs

3 POTENTIAL SIGNIFICANT ENVIRONMENTAL IMPACTS AND GOOD PRACTICE MITIGATION PROCEDURES

31 Positive Environnemental Impact

24 Most sub-projects financed by the SPPP that are well designed and properly implemented can have a positive impact on the environment The benefits of this type of sub-projects are often long term rather than short term and are not limited to the specific local community Examples of environmentally beneficial sub-projects that will be financed by the SPPP are subject to case by case assessment soil erosion protection protection of natural and cultural heritage sites

a Consultation and Public Disclosure

25 A simple approach is proposed for public consultation in the early stages of sub-project preparation and planning

The stakeholders should be made aware of the different elements and features of each sub-project and their main objectives and target groups Once an ESIA has been made the results of this study should be disclosed to all concerned primary stakeholders

The stakeholders should then be encouraged to share their concerns worries and any comments they have on the sub-project or its likely impacts This should include discussions on alternative and proposed mitigation measures that are to be accounted for in the sub-project design implementation and operation phases

The final step is to incorporate the stakeholder inputs into the sub-project plans in order to improve the sub-project design

26 The process of stakeholder involvement and consultation will continue during sub-project implementation as well in order to integrate any additional comments and worries that may arise from the construction and implementation phase

27 Consultation with the stakeholders may take different forms depending on the need and subject matter that is being communicated An informative method would be through the use of one-way communication techniques such as audio (radio) visual (television) printed (leaflets brochures pictures diagrams posters) or electronic media (internet and electronic mail) In this case the stakeholders will be merely informed with certain information and there shall be no opportunity for questions or comments In order to have interactive consultation with the

17

stakeholders two-way participatory techniques are required This may include one-to-one briefings small group and village meetings and the organization of workshops and forums

28 The technique used for the disclosure and dissemination of information and data should take into consideration stakeholder preferences and characteristics The disclosed information should be in a language that all stakeholders are familiar with and for those who are illiterate certain measures may need to be taken to ensure that they are fully aware of the contents of the disclosed documents Another important consideration is that ample time should be given to the stakeholders to review the disclosed information prior to the consultation process to allow them to thoroughly address the sub-projects various issues

29 The SPPP will also generate environmental benefits through a variety of other mechanisms among which are

(a)- Generation of environmental assessment guidelines that can be used by other organizations or ministries or could be adopted by the Ministry of Environment for more general use

(b)- Training of environmental specialists thus increasing the number of environmental professionals in the country

(c)- Improved environmental awareness in the local communities

b Future capacity building initiatives

30 These could be done through a structured training along two parallel lines (i) at the level of the implementing agencies when these are guided one by one through the process by the environmental specialist to help them look at the needed assessment and the mitigation measures if any (ii) at the level of the community by organizing awareness campaigns targeted to LCP and other prominent figures and other interested CSOs on environmental issues of relevance and how that affects the sub-projects implemented in their areas That creates a social accountability system that could be used to ensure that the sub-projects are implemented according to appropriate procedures

32 Negative Environmental Impacts

321 Overview of Negative Environmental Impacts

31 The SPPP will finance a considerable number of different types of subprojects An important percentage of the funding will be allocated for social development Though intended to improve environmental and social conditions these subprojects can have a variety of negative environmental impacts that might be encountered during the operation of the subprojects Environmental impacts arising from the operation of the different subprojects can be minimized by appropriate site selection good engineering design and appropriate construction techniques

4 IMPLEMENTATION ARRANGEMENTS

41 Environmental Guidelines

18

32 The implementation of the SPPP falls under the responsibility of MOSA who would be in charge of coordinating the various activities through its Social Development Centers (SDCs) with concerned local governments and NGOs A Project Coordination Team (PCT) will be established and would comprise experts with relevant experience in implementing similar projects and with proven capacity to handle all functions required in such a project Among its mandates the PCT will ensure that any sponsored subproject is environmentally sound and sustainable

33 The PCT shall ensure the following

Environmental considerations will be included as criteria for selecting activities to be supported by the project environmental assessment would become an integral part of the project cycle of any subproject

Environmental guidelines are followed and used throughout the project cycle

Environmental issues are introduced to beneficiaries through education and promotion of environmentally beneficial subprojects

34 The execution of the CSD will be undertaken by Civil Society Organizations (CSO) who would consist of qualified local authorities or national NGOs with strong community ties and proven execution capacity The SDC would assist local NGOs LCF and communities in identifying local needs preparing subprojects coordinating with concerned ministries and implementing the subprojects

42 Environmental Assessment (EA)

35 The World Bank Operational Policy (OP 401) on Environmental Assessment (January 1999) defines the Bankrsquos environmental assessment requirements to ensure that funded sub-projects are environmentally sound and sustainable A screening process is undertaken for all funded sub-projects to assess the magnitude and adversity of predicted environmental impacts and to determine the appropriate extent and type of EA Depending on the type location sensitivity and scale of the project as well as the nature and magnitude of environmental impacts sub-projects are classified into one of three categories

(a)- Category A Sub-Projects that are likely to cause significant and possibly irremediable environmental impacts

(b)- Category B Sub-Projects that might cause lesser adverse impacts than those of Category A and the impacts are often remediable or could be mitigated for

(c)- Category C Sub-Projects which could have minimal or no adverse environmental impacts

19

36 The SPPP will only fund sub-projects that can be classified as either Category B or Category C only For instance all income enhancement sub-projects will be classified as Category C while most social sub-projects will be Category B Sub-projects that are likely to cause substantial negative impacts and are expected to fall in Category A will not be approved for funding

37 This document will provide guidance with respect to the preparation of environmental assessment for the various funded subprojects These guidelines are based on the World Bank Operational Policies (OP 401) the Environmental Assessment Source book (1991) and its updates in addition to the Decree 86332012 on EA issued by the GOL

5 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

51 Objectives and Structure of the ESMP

38 The objectives of the ESMP are to mitigate the adverse environmental impacts identified in the SPPP The ESMP will consist of three kinds of activities

o Implementation of mitigation measures o Strengthening the capacities of PCT SDCs and local NGOs o Monitoring and evaluation of mitigation measures identified during subproject

formulation or within the environmental assessment report

52 Implementation of Mitigation Measures

39 Mitigation measures identified (Table 1) are for typical sub-projects and MOSAPCT will ensure that such measures are adhered to during the overall implementation of the SPPP

Table 1 Potential Environmental Impacts and Proposed Mitigation Measures for Different Subprojects

Project Component

Potential Impacts Mitigation Measures Responsibility

Roads rehabilitation

Clogging of natural drainage channelsEncroachment on private property

Dumping of construction wastes and accidental spills of machine fuels etcRisk of damage to unknown archaeological sites

Maintain ditches

Detailed property boundary surveys and flagging in fieldProper disposal of construction wastes

Use ldquochance findrdquo procedures and coordinate with appropriate

Contractor

ContractorIA

Contractor

IAsArcheology department

20

government agency

Rehabilitation of schools

Rehabilitation of health clinics

Irrigation and drainage

Improper disposal of wastes

Water quality degradation in ponds and reservoirsClogging of canals from weedssedimentsInefficient water flow because of heavy sedimentation

Degradation of water systems receiving irrigation waters by nutrients agrochemical and salts

Proper disposal of solid wastesPriority given to rehabilitation of toiletsInstallation of sanitation (cesspools)

Containerize infectious wastesPublic health awareness

Monitoring of water qualityOperation amp maintenance planProper design of canals and provision of access for weed and sediments removal

Control of agrochemical use

IAsMunicipality

IAscommunity

IAscommunity

Ministry of Health

Ministry of Energy and Water

IAs community

ContractorIAs

Ministry of Agriculturecommunity

53 Training Program and Capacity Building

40 The MOSA lacks the capacities and the expertise to work in the field of environmental monitoring and protection Moreover it is expected that the IAs mostly CSOs and SDCs do not have the needed resources to undertake the requirements needed in terms of EAs and designing mitigation measures This would require a detailed capacity building program that targets all levels of the decision making process in the project The central team at the MOSA and the PCT need to be oriented to the general approach to environmental safeguards importance use and how that could affect the selection implementation and monitoring of Sub-projects SDFCs and IAs should be trained on

21

the technical aspects of detection and mitigation and how these could be imbedded within the process of project identification to formulation to implementation These safeguards will have to be an integral part of any sub-project proposal and consequently any detailed action plan for any specific sub-project Environmental expertise within the implementing and executing bodies will be strengthened Training programs will designed and implemented with the assistance of a local or international expert and will target levels as stated in the Table 2 page 20

41 PCT and IAs At the initiation of the CSD and prior to bidding and selection of IAs a workshop will be provided and will include an environmental session to raise environmental awareness and to clarify the specific environmental requirements related to design and implementation of the SPPP

42 Another training workshop will be provided to the PCT and selected IAs and will cover the following to IAs

EIA techniques Screening sub-projects for environmental review Use of practical formschecklists Best environmental practices in design and implementation of projects Effective implementation of mitigation measures Project supervision Monitoring and evaluation

43 Local NGOs and Contractors IAs will be required to provide workshops for local NGOs and contractors focusing on public awareness case studies of environmental issues experienced in similar projects use of environmental guidelines and implementation of mitigation measures (Table 2 Annex III)

22

Table 2 Training and Capacity Building Program for Implementing the ESAFTraining

Capacity BuildingParticipating Stakeholders

Skills acquired Scheduling Cost Source

ManagementInstitutional

1year

SPPP manager MOSA central unit Head of concerned

departments at MOSA PCT

Decision making and delegation Work procedures Environmental awareness National guidelines WB guidelines Classification and mitigation

Prior to sub-project preparation Planning phase Refresher every 3 months as we

go along the project

Undertaken by the Environmental

SpecialistMiscellaneous

7500 USD

WBMOSA

Institutional at Intermediate levels

2 training sessions of 2 days year

(for SDC and IA X5 regions)

PCT Emanating committee SDC managers IAs

Environmental and social policies

Laws and regulations GOL and WB safeguards Evaluation and selection

During sub-project preparation Planning phase Sub-project evaluation

Undertaken by the Environmental

SpecialistMiscellaneous

30000 USD

WB MOSA

Implementation1 day session X2 year X 5 regions

IAs SDC staff Beneficiaries Municipalities

Environment and social tools Screening amp monitoring

methods Sustainability of the process Practical mitigation and

safeguards

During sub-project preparation Mobilization Implementation

Undertaken by the Environmental

SpecialistMiscellaneous

50000 USD

WB MOSA

Monitoring Evaluation and

Reporting1 dayX2 year X5

regions

IAs SDC staff Beneficiaries

Municipalities

Environmental and social monitoring and compliance

Progress report preparation Monitoring and Evaluation

During sub-project preparation MobilizationImplementation

Environmental Specialist + consultant

50000 USD

WB MOSA

Total 137500 USD (includes in kind contribution from MOSA)

23

54 Environmental Monitoring

44 Environmental Monitoring will be the responsibility of the ES PCT and MOSA Central Unit with the supervision of the LCP and will include compliance monitoring during implementation and also monitoring of significant impacts during the operation of the subproject

Table 3 Typical Examples of Monitoring Plan for the Operation of Different Subprojects

Sub-project Monitoring Indicators Responsibility FrequencyRoads rehabilitation

Operating drainage channels

NGOs in close coordination with local community

Semi-annual assessment

Improvements to Water Supply and Sanitation Facilities

Irrigation and drainage

Distribution network without leaksNo leakage or overflows of manholes or drainsWater Quality Monitoring

Irrigation network without leaksDrainage channels clean and properly maintainedWater quality parameters (pH COD BOD SS)

NGOs in close coordination with local community

Ministry of Health and Ministry of Energy and Water

NGOs in close coordination with local community

Testing by Ministry of Health and Ministry of Energy and Water

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Rehabilitation of schools

Rehabilitation of health clinics

Toilet facilities clean and functioning properlyDrinking water faucets clean and safe from contamination

NGOs in close coordination with local community and appropriate municipality

Ministry of Health in close coordination with local community

Semi-annual assessment

Semi-annual assessment

23

24

45 The Environmental Specialist (ES) of the PCT will also conduct periodic monitoring by visiting the sites of the various sub-projects at least twice during the implementation period of the sub-project

46 Monitoring indicators shall be developed for both the mobilization and the operation phase of the subprojects Monitoring of activities will have to ensure that mitigation measures of operations impacts are being implemented properly while the monitoring of operation is to ensure that no unforeseen negative impacts are arising

55 Sub-project Cycle

47 Component 2 of the SPPP is the Community Social Development Program (CSD) which will be financing community-based sub-projects through grants The Program will have two windows one for social services whereas the other is for Income Generation Activities (IGA) support with the review and approval mechanisms in large part being the same for both windows While Component 3 focuses on Poverty Targeting thus the services provided will have no impact on the environment component 1 will focus on the provision of technology and training to SDCs

48 Applicants will be invited to use standard forms (available on the MOSA website and upon request from SDCs) to submit proposals to the relevant SDC in cases where the applicant is the SDC itself the application will be submitted directly to the CSD program team in Beirut

49 SDCs will immediately check all proposals for completeness and give a receipt to the applicant with a proposal number proposals found to be incomplete will be rejected with an explanation All complete proposals will be presented for discussion to the relevant Local Community Platform (LCP) or equivalent consultative body to obtain feedback on among other things the actual need (in case of social services) or likely market value (in the case of IGA) of the proposed activity the reputation of the applicant the likely sustainability of the proposed activity the preliminary classification of the project within environmental categories (the final classification will be pending on the decision of the environmental specialist within the PCT) any problematic aspect (conflict of interest etc) and the overall compliance of the proposal with the purposes of the program This feedback is not binding but will be taken into consideration when deciding whether or not to fund the proposal The CSD program team will carry out a detailed desk review of all complete proposals to assess their technical quality as well as the budget and time line suggested for the sub-project The environmental specialist member of the Project Coordinating Team (PCT) will review the proposal and prepare all needed documentation based on his classification of the sub-project

56 Screening of Sub-Projects

50 Each sub-project to be implemented by an IA will be subjected to an environmental screening Using the screening form (Form 1) environmental and social checklists for the proposed sub-projects will be screened by the environmental specialist to identify any potential adverse impacts

25

From an environmental standpoint the screening form may identify impacts form sub-projects the issue of solid waste disposal at the site of a sub-project may come out as a point to look at in terms of designing mitigation measures to avoid negative impacts The selection of adequate storage collection and proper disposal could be steps to consider carefully

57 The Environmental and Social Screening Process

51 The objectives of sub-project screening is to determine which activities are likely to have negative environmental and social impacts

571 Subproject Screening Procedures

52 The sub-projects funded under this project are generally categorized as Category B or C and screening mechanisms would ensure that any identified Category A sub-projects are not funded under the project Due to the fact that most Category B sub-projects are small-scale which do not result in adverse negative environmental impacts this will require an ESMP which has clear due diligence environmental and social procedures (including the setting out of institutional responsibilities timing and budget) for sub-projects The ESMP should take into consideration the applicable requirements under the Bankrsquos ten safeguard policies

572 Environmental Sub-Project Screening Checklistsforms

53 The Operation Manual (OM) should contain for each type of sub-project a simple environmental screening checklist (Form 1)) which poses a series of questions designed to identify risks to the environment The goal of the checklist (also called a screening or environmental data sheet) is to identify which sub-projects require more environmental information in the form of a site-specific ESMP or which can proceed without any special mitigation measures that is falling under category C

Form 1 Environmental Screening Check-list

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

14

(i) Social Development (a) improving access to specialized social services to satisfy the needs of vulnerable groups at risk including the disabled children youth women and the elderly (b) enhancing environmental protection initiatives such as reforestation and soil erosion control wells and spring protection and preservation of natural sites

(ii) Income Enhancement Capacity building activities to support (a) micro and small entrepreneurs and non-governmental organizations providing credit to target beneficiary groups and (b) women youth and disabled people in order to provide them with demand driven specialized skills to improve their income and enhance their business opportunities

2 POLICY LEGAL amp INSTITUTIONAL FRAMEWORK FOR THE ENVIRONMENT

21 Regulatory Framework for Environmental Impact Assessment

20 Presently the environmental framework of Lebanon is managed and supervised by the Ministry of Environment (MOE) that was created by law 216 of April 2nd 1993 to be the government institution responsible for the development of a national strategy for sustainable development This was strengthened through the Law 4442002 Framework Law for the Protection of the Environment and the CEA (Country Environmental Analysis) The MOE is undergoing several review procedures to up-date the countryrsquos environmental policies and regulations including the preparation of an Environmental Code issuance of an Environmental Impact Assessment (EIA) decree as well as norms and standards for environmental protection The Environmental codes as well as the EIA decree were prepared with the assistance of the World Bank under the Mediterranean Environmental Technical Assistance Program (METAP) Also the World Bank has financed through METAP an assessment of the EIA System in Lebanon (Annex II)

METAP has also supported the establishment of an Environmental Management System Unit (EMSU) dealing with EIA at the MOE The concept of EA as part of project planning in Lebanon is still new and has only recently gained some attention The Environmental Impact Assessment (EIA) decree that was prepared by the MOE will require that an EIA be prepared during the planning process of both public and private development projects in Lebanon

22 Existing Environmental Legislation

221 International Conventions

21 The Lebanese Government has ratified a large number of international conventions for Environmental Protection Among the most important ones are

The Barcelona Convention for the protection of the Mediterranean SEA International Convention on World Heritage Protection International Convention on Bio-diversity Protection United Nations Convention on Desertification Montreal Protocol for the protection of the Ozone layer

15

222 Existing Lebanese Legislations

22 A list of the most significant existing environmental legislation is given in Annex II The primary safeguards as they are likely to affect SPPP subprojects are summarized in the following sections

Natural LandscapeProtection of the natural landscape of Lebanon was first addressed under the Law of January 1949 Recently cutting of trees was severely restricted under Decree No142 of March 1993 and further protection was provided under Law No 550 dated July 1996 There are also a number of Laws and Decisions that were issued to protect sites of particularly valuable landscape by declaring them Natural Reserves

Soil Water and Air PollutionProtection against pollution was first addressed by Decree No 8735 of October 1974 that prohibited the digging of wells for the disposal of raw sewage banned infiltration from cesspools and the use of sewage for the irrigation of vegetables and some fruits Decision No 521 of July 1996 introduced measures to deal with the pollution of the air water and soil including national standards for drinking water bathing waters and wastewater quality Recently Decision No 81 dated March 2001completed and reviewed the previously issued standards

Water ResourcesGround and surface water resources have been protected since the introduction of Order No 144 dated June 1925 which covered the major springs that supply the countryrsquos potable and irrigation needs Zoning of water sources and recharging of catchment areas was introduced by Decree 10276 of October 1962 to cope with increasing demand for water In 1970 Decree 14438 established a limit on the depth and exploitation of unlicensed wells and boreholes 150 m and 100 m3d respectively

Archaeological and Historical SitesThe protection of archaeological and historic sites was first addressed in Law No 1666 of November 1933 Later legislation has been introduced to afford special protection to the Cultural Heritage World Heritage and Cultural Landscape Sites declared by UNESCO

Public StreetsLaw No 60 of September 1983 covers Work in public streets law No 98 of September 1989 and by Circular 695 issued by the Prime Ministerrsquos Office on March 1995

Decree 86332012 on EIA describes clearly the various measures that need to be considered in the preliminary Environmental Evaluation of any project Projects found to require further investigation will have to be subjected to an EIA whereby complete set of information is required to allow for the Ministry to suggest needed mitigation measures and issue accordingly needed permits The stipulations of the decree go in hand with most of the WB guidelines The decree describes the various categories of sub-projects that do

16

require EIA and what are the projects that might cause risks and hazards A copy of the decree will be attached as an Annex to this document

23 Permit Procedures

23 Depending on the type and size of the sub-project to be executed and according to the Lebanese legislation a number of approvals and permits might be required from various governmental agencies In view of their nature and scale the majority of the sub-projects that would be funded by the SPPP will only require the approval of the municipality and or the Ministry of Municipalities and Rural Affairs

3 POTENTIAL SIGNIFICANT ENVIRONMENTAL IMPACTS AND GOOD PRACTICE MITIGATION PROCEDURES

31 Positive Environnemental Impact

24 Most sub-projects financed by the SPPP that are well designed and properly implemented can have a positive impact on the environment The benefits of this type of sub-projects are often long term rather than short term and are not limited to the specific local community Examples of environmentally beneficial sub-projects that will be financed by the SPPP are subject to case by case assessment soil erosion protection protection of natural and cultural heritage sites

a Consultation and Public Disclosure

25 A simple approach is proposed for public consultation in the early stages of sub-project preparation and planning

The stakeholders should be made aware of the different elements and features of each sub-project and their main objectives and target groups Once an ESIA has been made the results of this study should be disclosed to all concerned primary stakeholders

The stakeholders should then be encouraged to share their concerns worries and any comments they have on the sub-project or its likely impacts This should include discussions on alternative and proposed mitigation measures that are to be accounted for in the sub-project design implementation and operation phases

The final step is to incorporate the stakeholder inputs into the sub-project plans in order to improve the sub-project design

26 The process of stakeholder involvement and consultation will continue during sub-project implementation as well in order to integrate any additional comments and worries that may arise from the construction and implementation phase

27 Consultation with the stakeholders may take different forms depending on the need and subject matter that is being communicated An informative method would be through the use of one-way communication techniques such as audio (radio) visual (television) printed (leaflets brochures pictures diagrams posters) or electronic media (internet and electronic mail) In this case the stakeholders will be merely informed with certain information and there shall be no opportunity for questions or comments In order to have interactive consultation with the

17

stakeholders two-way participatory techniques are required This may include one-to-one briefings small group and village meetings and the organization of workshops and forums

28 The technique used for the disclosure and dissemination of information and data should take into consideration stakeholder preferences and characteristics The disclosed information should be in a language that all stakeholders are familiar with and for those who are illiterate certain measures may need to be taken to ensure that they are fully aware of the contents of the disclosed documents Another important consideration is that ample time should be given to the stakeholders to review the disclosed information prior to the consultation process to allow them to thoroughly address the sub-projects various issues

29 The SPPP will also generate environmental benefits through a variety of other mechanisms among which are

(a)- Generation of environmental assessment guidelines that can be used by other organizations or ministries or could be adopted by the Ministry of Environment for more general use

(b)- Training of environmental specialists thus increasing the number of environmental professionals in the country

(c)- Improved environmental awareness in the local communities

b Future capacity building initiatives

30 These could be done through a structured training along two parallel lines (i) at the level of the implementing agencies when these are guided one by one through the process by the environmental specialist to help them look at the needed assessment and the mitigation measures if any (ii) at the level of the community by organizing awareness campaigns targeted to LCP and other prominent figures and other interested CSOs on environmental issues of relevance and how that affects the sub-projects implemented in their areas That creates a social accountability system that could be used to ensure that the sub-projects are implemented according to appropriate procedures

32 Negative Environmental Impacts

321 Overview of Negative Environmental Impacts

31 The SPPP will finance a considerable number of different types of subprojects An important percentage of the funding will be allocated for social development Though intended to improve environmental and social conditions these subprojects can have a variety of negative environmental impacts that might be encountered during the operation of the subprojects Environmental impacts arising from the operation of the different subprojects can be minimized by appropriate site selection good engineering design and appropriate construction techniques

4 IMPLEMENTATION ARRANGEMENTS

41 Environmental Guidelines

18

32 The implementation of the SPPP falls under the responsibility of MOSA who would be in charge of coordinating the various activities through its Social Development Centers (SDCs) with concerned local governments and NGOs A Project Coordination Team (PCT) will be established and would comprise experts with relevant experience in implementing similar projects and with proven capacity to handle all functions required in such a project Among its mandates the PCT will ensure that any sponsored subproject is environmentally sound and sustainable

33 The PCT shall ensure the following

Environmental considerations will be included as criteria for selecting activities to be supported by the project environmental assessment would become an integral part of the project cycle of any subproject

Environmental guidelines are followed and used throughout the project cycle

Environmental issues are introduced to beneficiaries through education and promotion of environmentally beneficial subprojects

34 The execution of the CSD will be undertaken by Civil Society Organizations (CSO) who would consist of qualified local authorities or national NGOs with strong community ties and proven execution capacity The SDC would assist local NGOs LCF and communities in identifying local needs preparing subprojects coordinating with concerned ministries and implementing the subprojects

42 Environmental Assessment (EA)

35 The World Bank Operational Policy (OP 401) on Environmental Assessment (January 1999) defines the Bankrsquos environmental assessment requirements to ensure that funded sub-projects are environmentally sound and sustainable A screening process is undertaken for all funded sub-projects to assess the magnitude and adversity of predicted environmental impacts and to determine the appropriate extent and type of EA Depending on the type location sensitivity and scale of the project as well as the nature and magnitude of environmental impacts sub-projects are classified into one of three categories

(a)- Category A Sub-Projects that are likely to cause significant and possibly irremediable environmental impacts

(b)- Category B Sub-Projects that might cause lesser adverse impacts than those of Category A and the impacts are often remediable or could be mitigated for

(c)- Category C Sub-Projects which could have minimal or no adverse environmental impacts

19

36 The SPPP will only fund sub-projects that can be classified as either Category B or Category C only For instance all income enhancement sub-projects will be classified as Category C while most social sub-projects will be Category B Sub-projects that are likely to cause substantial negative impacts and are expected to fall in Category A will not be approved for funding

37 This document will provide guidance with respect to the preparation of environmental assessment for the various funded subprojects These guidelines are based on the World Bank Operational Policies (OP 401) the Environmental Assessment Source book (1991) and its updates in addition to the Decree 86332012 on EA issued by the GOL

5 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

51 Objectives and Structure of the ESMP

38 The objectives of the ESMP are to mitigate the adverse environmental impacts identified in the SPPP The ESMP will consist of three kinds of activities

o Implementation of mitigation measures o Strengthening the capacities of PCT SDCs and local NGOs o Monitoring and evaluation of mitigation measures identified during subproject

formulation or within the environmental assessment report

52 Implementation of Mitigation Measures

39 Mitigation measures identified (Table 1) are for typical sub-projects and MOSAPCT will ensure that such measures are adhered to during the overall implementation of the SPPP

Table 1 Potential Environmental Impacts and Proposed Mitigation Measures for Different Subprojects

Project Component

Potential Impacts Mitigation Measures Responsibility

Roads rehabilitation

Clogging of natural drainage channelsEncroachment on private property

Dumping of construction wastes and accidental spills of machine fuels etcRisk of damage to unknown archaeological sites

Maintain ditches

Detailed property boundary surveys and flagging in fieldProper disposal of construction wastes

Use ldquochance findrdquo procedures and coordinate with appropriate

Contractor

ContractorIA

Contractor

IAsArcheology department

20

government agency

Rehabilitation of schools

Rehabilitation of health clinics

Irrigation and drainage

Improper disposal of wastes

Water quality degradation in ponds and reservoirsClogging of canals from weedssedimentsInefficient water flow because of heavy sedimentation

Degradation of water systems receiving irrigation waters by nutrients agrochemical and salts

Proper disposal of solid wastesPriority given to rehabilitation of toiletsInstallation of sanitation (cesspools)

Containerize infectious wastesPublic health awareness

Monitoring of water qualityOperation amp maintenance planProper design of canals and provision of access for weed and sediments removal

Control of agrochemical use

IAsMunicipality

IAscommunity

IAscommunity

Ministry of Health

Ministry of Energy and Water

IAs community

ContractorIAs

Ministry of Agriculturecommunity

53 Training Program and Capacity Building

40 The MOSA lacks the capacities and the expertise to work in the field of environmental monitoring and protection Moreover it is expected that the IAs mostly CSOs and SDCs do not have the needed resources to undertake the requirements needed in terms of EAs and designing mitigation measures This would require a detailed capacity building program that targets all levels of the decision making process in the project The central team at the MOSA and the PCT need to be oriented to the general approach to environmental safeguards importance use and how that could affect the selection implementation and monitoring of Sub-projects SDFCs and IAs should be trained on

21

the technical aspects of detection and mitigation and how these could be imbedded within the process of project identification to formulation to implementation These safeguards will have to be an integral part of any sub-project proposal and consequently any detailed action plan for any specific sub-project Environmental expertise within the implementing and executing bodies will be strengthened Training programs will designed and implemented with the assistance of a local or international expert and will target levels as stated in the Table 2 page 20

41 PCT and IAs At the initiation of the CSD and prior to bidding and selection of IAs a workshop will be provided and will include an environmental session to raise environmental awareness and to clarify the specific environmental requirements related to design and implementation of the SPPP

42 Another training workshop will be provided to the PCT and selected IAs and will cover the following to IAs

EIA techniques Screening sub-projects for environmental review Use of practical formschecklists Best environmental practices in design and implementation of projects Effective implementation of mitigation measures Project supervision Monitoring and evaluation

43 Local NGOs and Contractors IAs will be required to provide workshops for local NGOs and contractors focusing on public awareness case studies of environmental issues experienced in similar projects use of environmental guidelines and implementation of mitigation measures (Table 2 Annex III)

22

Table 2 Training and Capacity Building Program for Implementing the ESAFTraining

Capacity BuildingParticipating Stakeholders

Skills acquired Scheduling Cost Source

ManagementInstitutional

1year

SPPP manager MOSA central unit Head of concerned

departments at MOSA PCT

Decision making and delegation Work procedures Environmental awareness National guidelines WB guidelines Classification and mitigation

Prior to sub-project preparation Planning phase Refresher every 3 months as we

go along the project

Undertaken by the Environmental

SpecialistMiscellaneous

7500 USD

WBMOSA

Institutional at Intermediate levels

2 training sessions of 2 days year

(for SDC and IA X5 regions)

PCT Emanating committee SDC managers IAs

Environmental and social policies

Laws and regulations GOL and WB safeguards Evaluation and selection

During sub-project preparation Planning phase Sub-project evaluation

Undertaken by the Environmental

SpecialistMiscellaneous

30000 USD

WB MOSA

Implementation1 day session X2 year X 5 regions

IAs SDC staff Beneficiaries Municipalities

Environment and social tools Screening amp monitoring

methods Sustainability of the process Practical mitigation and

safeguards

During sub-project preparation Mobilization Implementation

Undertaken by the Environmental

SpecialistMiscellaneous

50000 USD

WB MOSA

Monitoring Evaluation and

Reporting1 dayX2 year X5

regions

IAs SDC staff Beneficiaries

Municipalities

Environmental and social monitoring and compliance

Progress report preparation Monitoring and Evaluation

During sub-project preparation MobilizationImplementation

Environmental Specialist + consultant

50000 USD

WB MOSA

Total 137500 USD (includes in kind contribution from MOSA)

23

54 Environmental Monitoring

44 Environmental Monitoring will be the responsibility of the ES PCT and MOSA Central Unit with the supervision of the LCP and will include compliance monitoring during implementation and also monitoring of significant impacts during the operation of the subproject

Table 3 Typical Examples of Monitoring Plan for the Operation of Different Subprojects

Sub-project Monitoring Indicators Responsibility FrequencyRoads rehabilitation

Operating drainage channels

NGOs in close coordination with local community

Semi-annual assessment

Improvements to Water Supply and Sanitation Facilities

Irrigation and drainage

Distribution network without leaksNo leakage or overflows of manholes or drainsWater Quality Monitoring

Irrigation network without leaksDrainage channels clean and properly maintainedWater quality parameters (pH COD BOD SS)

NGOs in close coordination with local community

Ministry of Health and Ministry of Energy and Water

NGOs in close coordination with local community

Testing by Ministry of Health and Ministry of Energy and Water

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Rehabilitation of schools

Rehabilitation of health clinics

Toilet facilities clean and functioning properlyDrinking water faucets clean and safe from contamination

NGOs in close coordination with local community and appropriate municipality

Ministry of Health in close coordination with local community

Semi-annual assessment

Semi-annual assessment

23

24

45 The Environmental Specialist (ES) of the PCT will also conduct periodic monitoring by visiting the sites of the various sub-projects at least twice during the implementation period of the sub-project

46 Monitoring indicators shall be developed for both the mobilization and the operation phase of the subprojects Monitoring of activities will have to ensure that mitigation measures of operations impacts are being implemented properly while the monitoring of operation is to ensure that no unforeseen negative impacts are arising

55 Sub-project Cycle

47 Component 2 of the SPPP is the Community Social Development Program (CSD) which will be financing community-based sub-projects through grants The Program will have two windows one for social services whereas the other is for Income Generation Activities (IGA) support with the review and approval mechanisms in large part being the same for both windows While Component 3 focuses on Poverty Targeting thus the services provided will have no impact on the environment component 1 will focus on the provision of technology and training to SDCs

48 Applicants will be invited to use standard forms (available on the MOSA website and upon request from SDCs) to submit proposals to the relevant SDC in cases where the applicant is the SDC itself the application will be submitted directly to the CSD program team in Beirut

49 SDCs will immediately check all proposals for completeness and give a receipt to the applicant with a proposal number proposals found to be incomplete will be rejected with an explanation All complete proposals will be presented for discussion to the relevant Local Community Platform (LCP) or equivalent consultative body to obtain feedback on among other things the actual need (in case of social services) or likely market value (in the case of IGA) of the proposed activity the reputation of the applicant the likely sustainability of the proposed activity the preliminary classification of the project within environmental categories (the final classification will be pending on the decision of the environmental specialist within the PCT) any problematic aspect (conflict of interest etc) and the overall compliance of the proposal with the purposes of the program This feedback is not binding but will be taken into consideration when deciding whether or not to fund the proposal The CSD program team will carry out a detailed desk review of all complete proposals to assess their technical quality as well as the budget and time line suggested for the sub-project The environmental specialist member of the Project Coordinating Team (PCT) will review the proposal and prepare all needed documentation based on his classification of the sub-project

56 Screening of Sub-Projects

50 Each sub-project to be implemented by an IA will be subjected to an environmental screening Using the screening form (Form 1) environmental and social checklists for the proposed sub-projects will be screened by the environmental specialist to identify any potential adverse impacts

25

From an environmental standpoint the screening form may identify impacts form sub-projects the issue of solid waste disposal at the site of a sub-project may come out as a point to look at in terms of designing mitigation measures to avoid negative impacts The selection of adequate storage collection and proper disposal could be steps to consider carefully

57 The Environmental and Social Screening Process

51 The objectives of sub-project screening is to determine which activities are likely to have negative environmental and social impacts

571 Subproject Screening Procedures

52 The sub-projects funded under this project are generally categorized as Category B or C and screening mechanisms would ensure that any identified Category A sub-projects are not funded under the project Due to the fact that most Category B sub-projects are small-scale which do not result in adverse negative environmental impacts this will require an ESMP which has clear due diligence environmental and social procedures (including the setting out of institutional responsibilities timing and budget) for sub-projects The ESMP should take into consideration the applicable requirements under the Bankrsquos ten safeguard policies

572 Environmental Sub-Project Screening Checklistsforms

53 The Operation Manual (OM) should contain for each type of sub-project a simple environmental screening checklist (Form 1)) which poses a series of questions designed to identify risks to the environment The goal of the checklist (also called a screening or environmental data sheet) is to identify which sub-projects require more environmental information in the form of a site-specific ESMP or which can proceed without any special mitigation measures that is falling under category C

Form 1 Environmental Screening Check-list

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

15

222 Existing Lebanese Legislations

22 A list of the most significant existing environmental legislation is given in Annex II The primary safeguards as they are likely to affect SPPP subprojects are summarized in the following sections

Natural LandscapeProtection of the natural landscape of Lebanon was first addressed under the Law of January 1949 Recently cutting of trees was severely restricted under Decree No142 of March 1993 and further protection was provided under Law No 550 dated July 1996 There are also a number of Laws and Decisions that were issued to protect sites of particularly valuable landscape by declaring them Natural Reserves

Soil Water and Air PollutionProtection against pollution was first addressed by Decree No 8735 of October 1974 that prohibited the digging of wells for the disposal of raw sewage banned infiltration from cesspools and the use of sewage for the irrigation of vegetables and some fruits Decision No 521 of July 1996 introduced measures to deal with the pollution of the air water and soil including national standards for drinking water bathing waters and wastewater quality Recently Decision No 81 dated March 2001completed and reviewed the previously issued standards

Water ResourcesGround and surface water resources have been protected since the introduction of Order No 144 dated June 1925 which covered the major springs that supply the countryrsquos potable and irrigation needs Zoning of water sources and recharging of catchment areas was introduced by Decree 10276 of October 1962 to cope with increasing demand for water In 1970 Decree 14438 established a limit on the depth and exploitation of unlicensed wells and boreholes 150 m and 100 m3d respectively

Archaeological and Historical SitesThe protection of archaeological and historic sites was first addressed in Law No 1666 of November 1933 Later legislation has been introduced to afford special protection to the Cultural Heritage World Heritage and Cultural Landscape Sites declared by UNESCO

Public StreetsLaw No 60 of September 1983 covers Work in public streets law No 98 of September 1989 and by Circular 695 issued by the Prime Ministerrsquos Office on March 1995

Decree 86332012 on EIA describes clearly the various measures that need to be considered in the preliminary Environmental Evaluation of any project Projects found to require further investigation will have to be subjected to an EIA whereby complete set of information is required to allow for the Ministry to suggest needed mitigation measures and issue accordingly needed permits The stipulations of the decree go in hand with most of the WB guidelines The decree describes the various categories of sub-projects that do

16

require EIA and what are the projects that might cause risks and hazards A copy of the decree will be attached as an Annex to this document

23 Permit Procedures

23 Depending on the type and size of the sub-project to be executed and according to the Lebanese legislation a number of approvals and permits might be required from various governmental agencies In view of their nature and scale the majority of the sub-projects that would be funded by the SPPP will only require the approval of the municipality and or the Ministry of Municipalities and Rural Affairs

3 POTENTIAL SIGNIFICANT ENVIRONMENTAL IMPACTS AND GOOD PRACTICE MITIGATION PROCEDURES

31 Positive Environnemental Impact

24 Most sub-projects financed by the SPPP that are well designed and properly implemented can have a positive impact on the environment The benefits of this type of sub-projects are often long term rather than short term and are not limited to the specific local community Examples of environmentally beneficial sub-projects that will be financed by the SPPP are subject to case by case assessment soil erosion protection protection of natural and cultural heritage sites

a Consultation and Public Disclosure

25 A simple approach is proposed for public consultation in the early stages of sub-project preparation and planning

The stakeholders should be made aware of the different elements and features of each sub-project and their main objectives and target groups Once an ESIA has been made the results of this study should be disclosed to all concerned primary stakeholders

The stakeholders should then be encouraged to share their concerns worries and any comments they have on the sub-project or its likely impacts This should include discussions on alternative and proposed mitigation measures that are to be accounted for in the sub-project design implementation and operation phases

The final step is to incorporate the stakeholder inputs into the sub-project plans in order to improve the sub-project design

26 The process of stakeholder involvement and consultation will continue during sub-project implementation as well in order to integrate any additional comments and worries that may arise from the construction and implementation phase

27 Consultation with the stakeholders may take different forms depending on the need and subject matter that is being communicated An informative method would be through the use of one-way communication techniques such as audio (radio) visual (television) printed (leaflets brochures pictures diagrams posters) or electronic media (internet and electronic mail) In this case the stakeholders will be merely informed with certain information and there shall be no opportunity for questions or comments In order to have interactive consultation with the

17

stakeholders two-way participatory techniques are required This may include one-to-one briefings small group and village meetings and the organization of workshops and forums

28 The technique used for the disclosure and dissemination of information and data should take into consideration stakeholder preferences and characteristics The disclosed information should be in a language that all stakeholders are familiar with and for those who are illiterate certain measures may need to be taken to ensure that they are fully aware of the contents of the disclosed documents Another important consideration is that ample time should be given to the stakeholders to review the disclosed information prior to the consultation process to allow them to thoroughly address the sub-projects various issues

29 The SPPP will also generate environmental benefits through a variety of other mechanisms among which are

(a)- Generation of environmental assessment guidelines that can be used by other organizations or ministries or could be adopted by the Ministry of Environment for more general use

(b)- Training of environmental specialists thus increasing the number of environmental professionals in the country

(c)- Improved environmental awareness in the local communities

b Future capacity building initiatives

30 These could be done through a structured training along two parallel lines (i) at the level of the implementing agencies when these are guided one by one through the process by the environmental specialist to help them look at the needed assessment and the mitigation measures if any (ii) at the level of the community by organizing awareness campaigns targeted to LCP and other prominent figures and other interested CSOs on environmental issues of relevance and how that affects the sub-projects implemented in their areas That creates a social accountability system that could be used to ensure that the sub-projects are implemented according to appropriate procedures

32 Negative Environmental Impacts

321 Overview of Negative Environmental Impacts

31 The SPPP will finance a considerable number of different types of subprojects An important percentage of the funding will be allocated for social development Though intended to improve environmental and social conditions these subprojects can have a variety of negative environmental impacts that might be encountered during the operation of the subprojects Environmental impacts arising from the operation of the different subprojects can be minimized by appropriate site selection good engineering design and appropriate construction techniques

4 IMPLEMENTATION ARRANGEMENTS

41 Environmental Guidelines

18

32 The implementation of the SPPP falls under the responsibility of MOSA who would be in charge of coordinating the various activities through its Social Development Centers (SDCs) with concerned local governments and NGOs A Project Coordination Team (PCT) will be established and would comprise experts with relevant experience in implementing similar projects and with proven capacity to handle all functions required in such a project Among its mandates the PCT will ensure that any sponsored subproject is environmentally sound and sustainable

33 The PCT shall ensure the following

Environmental considerations will be included as criteria for selecting activities to be supported by the project environmental assessment would become an integral part of the project cycle of any subproject

Environmental guidelines are followed and used throughout the project cycle

Environmental issues are introduced to beneficiaries through education and promotion of environmentally beneficial subprojects

34 The execution of the CSD will be undertaken by Civil Society Organizations (CSO) who would consist of qualified local authorities or national NGOs with strong community ties and proven execution capacity The SDC would assist local NGOs LCF and communities in identifying local needs preparing subprojects coordinating with concerned ministries and implementing the subprojects

42 Environmental Assessment (EA)

35 The World Bank Operational Policy (OP 401) on Environmental Assessment (January 1999) defines the Bankrsquos environmental assessment requirements to ensure that funded sub-projects are environmentally sound and sustainable A screening process is undertaken for all funded sub-projects to assess the magnitude and adversity of predicted environmental impacts and to determine the appropriate extent and type of EA Depending on the type location sensitivity and scale of the project as well as the nature and magnitude of environmental impacts sub-projects are classified into one of three categories

(a)- Category A Sub-Projects that are likely to cause significant and possibly irremediable environmental impacts

(b)- Category B Sub-Projects that might cause lesser adverse impacts than those of Category A and the impacts are often remediable or could be mitigated for

(c)- Category C Sub-Projects which could have minimal or no adverse environmental impacts

19

36 The SPPP will only fund sub-projects that can be classified as either Category B or Category C only For instance all income enhancement sub-projects will be classified as Category C while most social sub-projects will be Category B Sub-projects that are likely to cause substantial negative impacts and are expected to fall in Category A will not be approved for funding

37 This document will provide guidance with respect to the preparation of environmental assessment for the various funded subprojects These guidelines are based on the World Bank Operational Policies (OP 401) the Environmental Assessment Source book (1991) and its updates in addition to the Decree 86332012 on EA issued by the GOL

5 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

51 Objectives and Structure of the ESMP

38 The objectives of the ESMP are to mitigate the adverse environmental impacts identified in the SPPP The ESMP will consist of three kinds of activities

o Implementation of mitigation measures o Strengthening the capacities of PCT SDCs and local NGOs o Monitoring and evaluation of mitigation measures identified during subproject

formulation or within the environmental assessment report

52 Implementation of Mitigation Measures

39 Mitigation measures identified (Table 1) are for typical sub-projects and MOSAPCT will ensure that such measures are adhered to during the overall implementation of the SPPP

Table 1 Potential Environmental Impacts and Proposed Mitigation Measures for Different Subprojects

Project Component

Potential Impacts Mitigation Measures Responsibility

Roads rehabilitation

Clogging of natural drainage channelsEncroachment on private property

Dumping of construction wastes and accidental spills of machine fuels etcRisk of damage to unknown archaeological sites

Maintain ditches

Detailed property boundary surveys and flagging in fieldProper disposal of construction wastes

Use ldquochance findrdquo procedures and coordinate with appropriate

Contractor

ContractorIA

Contractor

IAsArcheology department

20

government agency

Rehabilitation of schools

Rehabilitation of health clinics

Irrigation and drainage

Improper disposal of wastes

Water quality degradation in ponds and reservoirsClogging of canals from weedssedimentsInefficient water flow because of heavy sedimentation

Degradation of water systems receiving irrigation waters by nutrients agrochemical and salts

Proper disposal of solid wastesPriority given to rehabilitation of toiletsInstallation of sanitation (cesspools)

Containerize infectious wastesPublic health awareness

Monitoring of water qualityOperation amp maintenance planProper design of canals and provision of access for weed and sediments removal

Control of agrochemical use

IAsMunicipality

IAscommunity

IAscommunity

Ministry of Health

Ministry of Energy and Water

IAs community

ContractorIAs

Ministry of Agriculturecommunity

53 Training Program and Capacity Building

40 The MOSA lacks the capacities and the expertise to work in the field of environmental monitoring and protection Moreover it is expected that the IAs mostly CSOs and SDCs do not have the needed resources to undertake the requirements needed in terms of EAs and designing mitigation measures This would require a detailed capacity building program that targets all levels of the decision making process in the project The central team at the MOSA and the PCT need to be oriented to the general approach to environmental safeguards importance use and how that could affect the selection implementation and monitoring of Sub-projects SDFCs and IAs should be trained on

21

the technical aspects of detection and mitigation and how these could be imbedded within the process of project identification to formulation to implementation These safeguards will have to be an integral part of any sub-project proposal and consequently any detailed action plan for any specific sub-project Environmental expertise within the implementing and executing bodies will be strengthened Training programs will designed and implemented with the assistance of a local or international expert and will target levels as stated in the Table 2 page 20

41 PCT and IAs At the initiation of the CSD and prior to bidding and selection of IAs a workshop will be provided and will include an environmental session to raise environmental awareness and to clarify the specific environmental requirements related to design and implementation of the SPPP

42 Another training workshop will be provided to the PCT and selected IAs and will cover the following to IAs

EIA techniques Screening sub-projects for environmental review Use of practical formschecklists Best environmental practices in design and implementation of projects Effective implementation of mitigation measures Project supervision Monitoring and evaluation

43 Local NGOs and Contractors IAs will be required to provide workshops for local NGOs and contractors focusing on public awareness case studies of environmental issues experienced in similar projects use of environmental guidelines and implementation of mitigation measures (Table 2 Annex III)

22

Table 2 Training and Capacity Building Program for Implementing the ESAFTraining

Capacity BuildingParticipating Stakeholders

Skills acquired Scheduling Cost Source

ManagementInstitutional

1year

SPPP manager MOSA central unit Head of concerned

departments at MOSA PCT

Decision making and delegation Work procedures Environmental awareness National guidelines WB guidelines Classification and mitigation

Prior to sub-project preparation Planning phase Refresher every 3 months as we

go along the project

Undertaken by the Environmental

SpecialistMiscellaneous

7500 USD

WBMOSA

Institutional at Intermediate levels

2 training sessions of 2 days year

(for SDC and IA X5 regions)

PCT Emanating committee SDC managers IAs

Environmental and social policies

Laws and regulations GOL and WB safeguards Evaluation and selection

During sub-project preparation Planning phase Sub-project evaluation

Undertaken by the Environmental

SpecialistMiscellaneous

30000 USD

WB MOSA

Implementation1 day session X2 year X 5 regions

IAs SDC staff Beneficiaries Municipalities

Environment and social tools Screening amp monitoring

methods Sustainability of the process Practical mitigation and

safeguards

During sub-project preparation Mobilization Implementation

Undertaken by the Environmental

SpecialistMiscellaneous

50000 USD

WB MOSA

Monitoring Evaluation and

Reporting1 dayX2 year X5

regions

IAs SDC staff Beneficiaries

Municipalities

Environmental and social monitoring and compliance

Progress report preparation Monitoring and Evaluation

During sub-project preparation MobilizationImplementation

Environmental Specialist + consultant

50000 USD

WB MOSA

Total 137500 USD (includes in kind contribution from MOSA)

23

54 Environmental Monitoring

44 Environmental Monitoring will be the responsibility of the ES PCT and MOSA Central Unit with the supervision of the LCP and will include compliance monitoring during implementation and also monitoring of significant impacts during the operation of the subproject

Table 3 Typical Examples of Monitoring Plan for the Operation of Different Subprojects

Sub-project Monitoring Indicators Responsibility FrequencyRoads rehabilitation

Operating drainage channels

NGOs in close coordination with local community

Semi-annual assessment

Improvements to Water Supply and Sanitation Facilities

Irrigation and drainage

Distribution network without leaksNo leakage or overflows of manholes or drainsWater Quality Monitoring

Irrigation network without leaksDrainage channels clean and properly maintainedWater quality parameters (pH COD BOD SS)

NGOs in close coordination with local community

Ministry of Health and Ministry of Energy and Water

NGOs in close coordination with local community

Testing by Ministry of Health and Ministry of Energy and Water

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Rehabilitation of schools

Rehabilitation of health clinics

Toilet facilities clean and functioning properlyDrinking water faucets clean and safe from contamination

NGOs in close coordination with local community and appropriate municipality

Ministry of Health in close coordination with local community

Semi-annual assessment

Semi-annual assessment

23

24

45 The Environmental Specialist (ES) of the PCT will also conduct periodic monitoring by visiting the sites of the various sub-projects at least twice during the implementation period of the sub-project

46 Monitoring indicators shall be developed for both the mobilization and the operation phase of the subprojects Monitoring of activities will have to ensure that mitigation measures of operations impacts are being implemented properly while the monitoring of operation is to ensure that no unforeseen negative impacts are arising

55 Sub-project Cycle

47 Component 2 of the SPPP is the Community Social Development Program (CSD) which will be financing community-based sub-projects through grants The Program will have two windows one for social services whereas the other is for Income Generation Activities (IGA) support with the review and approval mechanisms in large part being the same for both windows While Component 3 focuses on Poverty Targeting thus the services provided will have no impact on the environment component 1 will focus on the provision of technology and training to SDCs

48 Applicants will be invited to use standard forms (available on the MOSA website and upon request from SDCs) to submit proposals to the relevant SDC in cases where the applicant is the SDC itself the application will be submitted directly to the CSD program team in Beirut

49 SDCs will immediately check all proposals for completeness and give a receipt to the applicant with a proposal number proposals found to be incomplete will be rejected with an explanation All complete proposals will be presented for discussion to the relevant Local Community Platform (LCP) or equivalent consultative body to obtain feedback on among other things the actual need (in case of social services) or likely market value (in the case of IGA) of the proposed activity the reputation of the applicant the likely sustainability of the proposed activity the preliminary classification of the project within environmental categories (the final classification will be pending on the decision of the environmental specialist within the PCT) any problematic aspect (conflict of interest etc) and the overall compliance of the proposal with the purposes of the program This feedback is not binding but will be taken into consideration when deciding whether or not to fund the proposal The CSD program team will carry out a detailed desk review of all complete proposals to assess their technical quality as well as the budget and time line suggested for the sub-project The environmental specialist member of the Project Coordinating Team (PCT) will review the proposal and prepare all needed documentation based on his classification of the sub-project

56 Screening of Sub-Projects

50 Each sub-project to be implemented by an IA will be subjected to an environmental screening Using the screening form (Form 1) environmental and social checklists for the proposed sub-projects will be screened by the environmental specialist to identify any potential adverse impacts

25

From an environmental standpoint the screening form may identify impacts form sub-projects the issue of solid waste disposal at the site of a sub-project may come out as a point to look at in terms of designing mitigation measures to avoid negative impacts The selection of adequate storage collection and proper disposal could be steps to consider carefully

57 The Environmental and Social Screening Process

51 The objectives of sub-project screening is to determine which activities are likely to have negative environmental and social impacts

571 Subproject Screening Procedures

52 The sub-projects funded under this project are generally categorized as Category B or C and screening mechanisms would ensure that any identified Category A sub-projects are not funded under the project Due to the fact that most Category B sub-projects are small-scale which do not result in adverse negative environmental impacts this will require an ESMP which has clear due diligence environmental and social procedures (including the setting out of institutional responsibilities timing and budget) for sub-projects The ESMP should take into consideration the applicable requirements under the Bankrsquos ten safeguard policies

572 Environmental Sub-Project Screening Checklistsforms

53 The Operation Manual (OM) should contain for each type of sub-project a simple environmental screening checklist (Form 1)) which poses a series of questions designed to identify risks to the environment The goal of the checklist (also called a screening or environmental data sheet) is to identify which sub-projects require more environmental information in the form of a site-specific ESMP or which can proceed without any special mitigation measures that is falling under category C

Form 1 Environmental Screening Check-list

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

16

require EIA and what are the projects that might cause risks and hazards A copy of the decree will be attached as an Annex to this document

23 Permit Procedures

23 Depending on the type and size of the sub-project to be executed and according to the Lebanese legislation a number of approvals and permits might be required from various governmental agencies In view of their nature and scale the majority of the sub-projects that would be funded by the SPPP will only require the approval of the municipality and or the Ministry of Municipalities and Rural Affairs

3 POTENTIAL SIGNIFICANT ENVIRONMENTAL IMPACTS AND GOOD PRACTICE MITIGATION PROCEDURES

31 Positive Environnemental Impact

24 Most sub-projects financed by the SPPP that are well designed and properly implemented can have a positive impact on the environment The benefits of this type of sub-projects are often long term rather than short term and are not limited to the specific local community Examples of environmentally beneficial sub-projects that will be financed by the SPPP are subject to case by case assessment soil erosion protection protection of natural and cultural heritage sites

a Consultation and Public Disclosure

25 A simple approach is proposed for public consultation in the early stages of sub-project preparation and planning

The stakeholders should be made aware of the different elements and features of each sub-project and their main objectives and target groups Once an ESIA has been made the results of this study should be disclosed to all concerned primary stakeholders

The stakeholders should then be encouraged to share their concerns worries and any comments they have on the sub-project or its likely impacts This should include discussions on alternative and proposed mitigation measures that are to be accounted for in the sub-project design implementation and operation phases

The final step is to incorporate the stakeholder inputs into the sub-project plans in order to improve the sub-project design

26 The process of stakeholder involvement and consultation will continue during sub-project implementation as well in order to integrate any additional comments and worries that may arise from the construction and implementation phase

27 Consultation with the stakeholders may take different forms depending on the need and subject matter that is being communicated An informative method would be through the use of one-way communication techniques such as audio (radio) visual (television) printed (leaflets brochures pictures diagrams posters) or electronic media (internet and electronic mail) In this case the stakeholders will be merely informed with certain information and there shall be no opportunity for questions or comments In order to have interactive consultation with the

17

stakeholders two-way participatory techniques are required This may include one-to-one briefings small group and village meetings and the organization of workshops and forums

28 The technique used for the disclosure and dissemination of information and data should take into consideration stakeholder preferences and characteristics The disclosed information should be in a language that all stakeholders are familiar with and for those who are illiterate certain measures may need to be taken to ensure that they are fully aware of the contents of the disclosed documents Another important consideration is that ample time should be given to the stakeholders to review the disclosed information prior to the consultation process to allow them to thoroughly address the sub-projects various issues

29 The SPPP will also generate environmental benefits through a variety of other mechanisms among which are

(a)- Generation of environmental assessment guidelines that can be used by other organizations or ministries or could be adopted by the Ministry of Environment for more general use

(b)- Training of environmental specialists thus increasing the number of environmental professionals in the country

(c)- Improved environmental awareness in the local communities

b Future capacity building initiatives

30 These could be done through a structured training along two parallel lines (i) at the level of the implementing agencies when these are guided one by one through the process by the environmental specialist to help them look at the needed assessment and the mitigation measures if any (ii) at the level of the community by organizing awareness campaigns targeted to LCP and other prominent figures and other interested CSOs on environmental issues of relevance and how that affects the sub-projects implemented in their areas That creates a social accountability system that could be used to ensure that the sub-projects are implemented according to appropriate procedures

32 Negative Environmental Impacts

321 Overview of Negative Environmental Impacts

31 The SPPP will finance a considerable number of different types of subprojects An important percentage of the funding will be allocated for social development Though intended to improve environmental and social conditions these subprojects can have a variety of negative environmental impacts that might be encountered during the operation of the subprojects Environmental impacts arising from the operation of the different subprojects can be minimized by appropriate site selection good engineering design and appropriate construction techniques

4 IMPLEMENTATION ARRANGEMENTS

41 Environmental Guidelines

18

32 The implementation of the SPPP falls under the responsibility of MOSA who would be in charge of coordinating the various activities through its Social Development Centers (SDCs) with concerned local governments and NGOs A Project Coordination Team (PCT) will be established and would comprise experts with relevant experience in implementing similar projects and with proven capacity to handle all functions required in such a project Among its mandates the PCT will ensure that any sponsored subproject is environmentally sound and sustainable

33 The PCT shall ensure the following

Environmental considerations will be included as criteria for selecting activities to be supported by the project environmental assessment would become an integral part of the project cycle of any subproject

Environmental guidelines are followed and used throughout the project cycle

Environmental issues are introduced to beneficiaries through education and promotion of environmentally beneficial subprojects

34 The execution of the CSD will be undertaken by Civil Society Organizations (CSO) who would consist of qualified local authorities or national NGOs with strong community ties and proven execution capacity The SDC would assist local NGOs LCF and communities in identifying local needs preparing subprojects coordinating with concerned ministries and implementing the subprojects

42 Environmental Assessment (EA)

35 The World Bank Operational Policy (OP 401) on Environmental Assessment (January 1999) defines the Bankrsquos environmental assessment requirements to ensure that funded sub-projects are environmentally sound and sustainable A screening process is undertaken for all funded sub-projects to assess the magnitude and adversity of predicted environmental impacts and to determine the appropriate extent and type of EA Depending on the type location sensitivity and scale of the project as well as the nature and magnitude of environmental impacts sub-projects are classified into one of three categories

(a)- Category A Sub-Projects that are likely to cause significant and possibly irremediable environmental impacts

(b)- Category B Sub-Projects that might cause lesser adverse impacts than those of Category A and the impacts are often remediable or could be mitigated for

(c)- Category C Sub-Projects which could have minimal or no adverse environmental impacts

19

36 The SPPP will only fund sub-projects that can be classified as either Category B or Category C only For instance all income enhancement sub-projects will be classified as Category C while most social sub-projects will be Category B Sub-projects that are likely to cause substantial negative impacts and are expected to fall in Category A will not be approved for funding

37 This document will provide guidance with respect to the preparation of environmental assessment for the various funded subprojects These guidelines are based on the World Bank Operational Policies (OP 401) the Environmental Assessment Source book (1991) and its updates in addition to the Decree 86332012 on EA issued by the GOL

5 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

51 Objectives and Structure of the ESMP

38 The objectives of the ESMP are to mitigate the adverse environmental impacts identified in the SPPP The ESMP will consist of three kinds of activities

o Implementation of mitigation measures o Strengthening the capacities of PCT SDCs and local NGOs o Monitoring and evaluation of mitigation measures identified during subproject

formulation or within the environmental assessment report

52 Implementation of Mitigation Measures

39 Mitigation measures identified (Table 1) are for typical sub-projects and MOSAPCT will ensure that such measures are adhered to during the overall implementation of the SPPP

Table 1 Potential Environmental Impacts and Proposed Mitigation Measures for Different Subprojects

Project Component

Potential Impacts Mitigation Measures Responsibility

Roads rehabilitation

Clogging of natural drainage channelsEncroachment on private property

Dumping of construction wastes and accidental spills of machine fuels etcRisk of damage to unknown archaeological sites

Maintain ditches

Detailed property boundary surveys and flagging in fieldProper disposal of construction wastes

Use ldquochance findrdquo procedures and coordinate with appropriate

Contractor

ContractorIA

Contractor

IAsArcheology department

20

government agency

Rehabilitation of schools

Rehabilitation of health clinics

Irrigation and drainage

Improper disposal of wastes

Water quality degradation in ponds and reservoirsClogging of canals from weedssedimentsInefficient water flow because of heavy sedimentation

Degradation of water systems receiving irrigation waters by nutrients agrochemical and salts

Proper disposal of solid wastesPriority given to rehabilitation of toiletsInstallation of sanitation (cesspools)

Containerize infectious wastesPublic health awareness

Monitoring of water qualityOperation amp maintenance planProper design of canals and provision of access for weed and sediments removal

Control of agrochemical use

IAsMunicipality

IAscommunity

IAscommunity

Ministry of Health

Ministry of Energy and Water

IAs community

ContractorIAs

Ministry of Agriculturecommunity

53 Training Program and Capacity Building

40 The MOSA lacks the capacities and the expertise to work in the field of environmental monitoring and protection Moreover it is expected that the IAs mostly CSOs and SDCs do not have the needed resources to undertake the requirements needed in terms of EAs and designing mitigation measures This would require a detailed capacity building program that targets all levels of the decision making process in the project The central team at the MOSA and the PCT need to be oriented to the general approach to environmental safeguards importance use and how that could affect the selection implementation and monitoring of Sub-projects SDFCs and IAs should be trained on

21

the technical aspects of detection and mitigation and how these could be imbedded within the process of project identification to formulation to implementation These safeguards will have to be an integral part of any sub-project proposal and consequently any detailed action plan for any specific sub-project Environmental expertise within the implementing and executing bodies will be strengthened Training programs will designed and implemented with the assistance of a local or international expert and will target levels as stated in the Table 2 page 20

41 PCT and IAs At the initiation of the CSD and prior to bidding and selection of IAs a workshop will be provided and will include an environmental session to raise environmental awareness and to clarify the specific environmental requirements related to design and implementation of the SPPP

42 Another training workshop will be provided to the PCT and selected IAs and will cover the following to IAs

EIA techniques Screening sub-projects for environmental review Use of practical formschecklists Best environmental practices in design and implementation of projects Effective implementation of mitigation measures Project supervision Monitoring and evaluation

43 Local NGOs and Contractors IAs will be required to provide workshops for local NGOs and contractors focusing on public awareness case studies of environmental issues experienced in similar projects use of environmental guidelines and implementation of mitigation measures (Table 2 Annex III)

22

Table 2 Training and Capacity Building Program for Implementing the ESAFTraining

Capacity BuildingParticipating Stakeholders

Skills acquired Scheduling Cost Source

ManagementInstitutional

1year

SPPP manager MOSA central unit Head of concerned

departments at MOSA PCT

Decision making and delegation Work procedures Environmental awareness National guidelines WB guidelines Classification and mitigation

Prior to sub-project preparation Planning phase Refresher every 3 months as we

go along the project

Undertaken by the Environmental

SpecialistMiscellaneous

7500 USD

WBMOSA

Institutional at Intermediate levels

2 training sessions of 2 days year

(for SDC and IA X5 regions)

PCT Emanating committee SDC managers IAs

Environmental and social policies

Laws and regulations GOL and WB safeguards Evaluation and selection

During sub-project preparation Planning phase Sub-project evaluation

Undertaken by the Environmental

SpecialistMiscellaneous

30000 USD

WB MOSA

Implementation1 day session X2 year X 5 regions

IAs SDC staff Beneficiaries Municipalities

Environment and social tools Screening amp monitoring

methods Sustainability of the process Practical mitigation and

safeguards

During sub-project preparation Mobilization Implementation

Undertaken by the Environmental

SpecialistMiscellaneous

50000 USD

WB MOSA

Monitoring Evaluation and

Reporting1 dayX2 year X5

regions

IAs SDC staff Beneficiaries

Municipalities

Environmental and social monitoring and compliance

Progress report preparation Monitoring and Evaluation

During sub-project preparation MobilizationImplementation

Environmental Specialist + consultant

50000 USD

WB MOSA

Total 137500 USD (includes in kind contribution from MOSA)

23

54 Environmental Monitoring

44 Environmental Monitoring will be the responsibility of the ES PCT and MOSA Central Unit with the supervision of the LCP and will include compliance monitoring during implementation and also monitoring of significant impacts during the operation of the subproject

Table 3 Typical Examples of Monitoring Plan for the Operation of Different Subprojects

Sub-project Monitoring Indicators Responsibility FrequencyRoads rehabilitation

Operating drainage channels

NGOs in close coordination with local community

Semi-annual assessment

Improvements to Water Supply and Sanitation Facilities

Irrigation and drainage

Distribution network without leaksNo leakage or overflows of manholes or drainsWater Quality Monitoring

Irrigation network without leaksDrainage channels clean and properly maintainedWater quality parameters (pH COD BOD SS)

NGOs in close coordination with local community

Ministry of Health and Ministry of Energy and Water

NGOs in close coordination with local community

Testing by Ministry of Health and Ministry of Energy and Water

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Rehabilitation of schools

Rehabilitation of health clinics

Toilet facilities clean and functioning properlyDrinking water faucets clean and safe from contamination

NGOs in close coordination with local community and appropriate municipality

Ministry of Health in close coordination with local community

Semi-annual assessment

Semi-annual assessment

23

24

45 The Environmental Specialist (ES) of the PCT will also conduct periodic monitoring by visiting the sites of the various sub-projects at least twice during the implementation period of the sub-project

46 Monitoring indicators shall be developed for both the mobilization and the operation phase of the subprojects Monitoring of activities will have to ensure that mitigation measures of operations impacts are being implemented properly while the monitoring of operation is to ensure that no unforeseen negative impacts are arising

55 Sub-project Cycle

47 Component 2 of the SPPP is the Community Social Development Program (CSD) which will be financing community-based sub-projects through grants The Program will have two windows one for social services whereas the other is for Income Generation Activities (IGA) support with the review and approval mechanisms in large part being the same for both windows While Component 3 focuses on Poverty Targeting thus the services provided will have no impact on the environment component 1 will focus on the provision of technology and training to SDCs

48 Applicants will be invited to use standard forms (available on the MOSA website and upon request from SDCs) to submit proposals to the relevant SDC in cases where the applicant is the SDC itself the application will be submitted directly to the CSD program team in Beirut

49 SDCs will immediately check all proposals for completeness and give a receipt to the applicant with a proposal number proposals found to be incomplete will be rejected with an explanation All complete proposals will be presented for discussion to the relevant Local Community Platform (LCP) or equivalent consultative body to obtain feedback on among other things the actual need (in case of social services) or likely market value (in the case of IGA) of the proposed activity the reputation of the applicant the likely sustainability of the proposed activity the preliminary classification of the project within environmental categories (the final classification will be pending on the decision of the environmental specialist within the PCT) any problematic aspect (conflict of interest etc) and the overall compliance of the proposal with the purposes of the program This feedback is not binding but will be taken into consideration when deciding whether or not to fund the proposal The CSD program team will carry out a detailed desk review of all complete proposals to assess their technical quality as well as the budget and time line suggested for the sub-project The environmental specialist member of the Project Coordinating Team (PCT) will review the proposal and prepare all needed documentation based on his classification of the sub-project

56 Screening of Sub-Projects

50 Each sub-project to be implemented by an IA will be subjected to an environmental screening Using the screening form (Form 1) environmental and social checklists for the proposed sub-projects will be screened by the environmental specialist to identify any potential adverse impacts

25

From an environmental standpoint the screening form may identify impacts form sub-projects the issue of solid waste disposal at the site of a sub-project may come out as a point to look at in terms of designing mitigation measures to avoid negative impacts The selection of adequate storage collection and proper disposal could be steps to consider carefully

57 The Environmental and Social Screening Process

51 The objectives of sub-project screening is to determine which activities are likely to have negative environmental and social impacts

571 Subproject Screening Procedures

52 The sub-projects funded under this project are generally categorized as Category B or C and screening mechanisms would ensure that any identified Category A sub-projects are not funded under the project Due to the fact that most Category B sub-projects are small-scale which do not result in adverse negative environmental impacts this will require an ESMP which has clear due diligence environmental and social procedures (including the setting out of institutional responsibilities timing and budget) for sub-projects The ESMP should take into consideration the applicable requirements under the Bankrsquos ten safeguard policies

572 Environmental Sub-Project Screening Checklistsforms

53 The Operation Manual (OM) should contain for each type of sub-project a simple environmental screening checklist (Form 1)) which poses a series of questions designed to identify risks to the environment The goal of the checklist (also called a screening or environmental data sheet) is to identify which sub-projects require more environmental information in the form of a site-specific ESMP or which can proceed without any special mitigation measures that is falling under category C

Form 1 Environmental Screening Check-list

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

17

stakeholders two-way participatory techniques are required This may include one-to-one briefings small group and village meetings and the organization of workshops and forums

28 The technique used for the disclosure and dissemination of information and data should take into consideration stakeholder preferences and characteristics The disclosed information should be in a language that all stakeholders are familiar with and for those who are illiterate certain measures may need to be taken to ensure that they are fully aware of the contents of the disclosed documents Another important consideration is that ample time should be given to the stakeholders to review the disclosed information prior to the consultation process to allow them to thoroughly address the sub-projects various issues

29 The SPPP will also generate environmental benefits through a variety of other mechanisms among which are

(a)- Generation of environmental assessment guidelines that can be used by other organizations or ministries or could be adopted by the Ministry of Environment for more general use

(b)- Training of environmental specialists thus increasing the number of environmental professionals in the country

(c)- Improved environmental awareness in the local communities

b Future capacity building initiatives

30 These could be done through a structured training along two parallel lines (i) at the level of the implementing agencies when these are guided one by one through the process by the environmental specialist to help them look at the needed assessment and the mitigation measures if any (ii) at the level of the community by organizing awareness campaigns targeted to LCP and other prominent figures and other interested CSOs on environmental issues of relevance and how that affects the sub-projects implemented in their areas That creates a social accountability system that could be used to ensure that the sub-projects are implemented according to appropriate procedures

32 Negative Environmental Impacts

321 Overview of Negative Environmental Impacts

31 The SPPP will finance a considerable number of different types of subprojects An important percentage of the funding will be allocated for social development Though intended to improve environmental and social conditions these subprojects can have a variety of negative environmental impacts that might be encountered during the operation of the subprojects Environmental impacts arising from the operation of the different subprojects can be minimized by appropriate site selection good engineering design and appropriate construction techniques

4 IMPLEMENTATION ARRANGEMENTS

41 Environmental Guidelines

18

32 The implementation of the SPPP falls under the responsibility of MOSA who would be in charge of coordinating the various activities through its Social Development Centers (SDCs) with concerned local governments and NGOs A Project Coordination Team (PCT) will be established and would comprise experts with relevant experience in implementing similar projects and with proven capacity to handle all functions required in such a project Among its mandates the PCT will ensure that any sponsored subproject is environmentally sound and sustainable

33 The PCT shall ensure the following

Environmental considerations will be included as criteria for selecting activities to be supported by the project environmental assessment would become an integral part of the project cycle of any subproject

Environmental guidelines are followed and used throughout the project cycle

Environmental issues are introduced to beneficiaries through education and promotion of environmentally beneficial subprojects

34 The execution of the CSD will be undertaken by Civil Society Organizations (CSO) who would consist of qualified local authorities or national NGOs with strong community ties and proven execution capacity The SDC would assist local NGOs LCF and communities in identifying local needs preparing subprojects coordinating with concerned ministries and implementing the subprojects

42 Environmental Assessment (EA)

35 The World Bank Operational Policy (OP 401) on Environmental Assessment (January 1999) defines the Bankrsquos environmental assessment requirements to ensure that funded sub-projects are environmentally sound and sustainable A screening process is undertaken for all funded sub-projects to assess the magnitude and adversity of predicted environmental impacts and to determine the appropriate extent and type of EA Depending on the type location sensitivity and scale of the project as well as the nature and magnitude of environmental impacts sub-projects are classified into one of three categories

(a)- Category A Sub-Projects that are likely to cause significant and possibly irremediable environmental impacts

(b)- Category B Sub-Projects that might cause lesser adverse impacts than those of Category A and the impacts are often remediable or could be mitigated for

(c)- Category C Sub-Projects which could have minimal or no adverse environmental impacts

19

36 The SPPP will only fund sub-projects that can be classified as either Category B or Category C only For instance all income enhancement sub-projects will be classified as Category C while most social sub-projects will be Category B Sub-projects that are likely to cause substantial negative impacts and are expected to fall in Category A will not be approved for funding

37 This document will provide guidance with respect to the preparation of environmental assessment for the various funded subprojects These guidelines are based on the World Bank Operational Policies (OP 401) the Environmental Assessment Source book (1991) and its updates in addition to the Decree 86332012 on EA issued by the GOL

5 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

51 Objectives and Structure of the ESMP

38 The objectives of the ESMP are to mitigate the adverse environmental impacts identified in the SPPP The ESMP will consist of three kinds of activities

o Implementation of mitigation measures o Strengthening the capacities of PCT SDCs and local NGOs o Monitoring and evaluation of mitigation measures identified during subproject

formulation or within the environmental assessment report

52 Implementation of Mitigation Measures

39 Mitigation measures identified (Table 1) are for typical sub-projects and MOSAPCT will ensure that such measures are adhered to during the overall implementation of the SPPP

Table 1 Potential Environmental Impacts and Proposed Mitigation Measures for Different Subprojects

Project Component

Potential Impacts Mitigation Measures Responsibility

Roads rehabilitation

Clogging of natural drainage channelsEncroachment on private property

Dumping of construction wastes and accidental spills of machine fuels etcRisk of damage to unknown archaeological sites

Maintain ditches

Detailed property boundary surveys and flagging in fieldProper disposal of construction wastes

Use ldquochance findrdquo procedures and coordinate with appropriate

Contractor

ContractorIA

Contractor

IAsArcheology department

20

government agency

Rehabilitation of schools

Rehabilitation of health clinics

Irrigation and drainage

Improper disposal of wastes

Water quality degradation in ponds and reservoirsClogging of canals from weedssedimentsInefficient water flow because of heavy sedimentation

Degradation of water systems receiving irrigation waters by nutrients agrochemical and salts

Proper disposal of solid wastesPriority given to rehabilitation of toiletsInstallation of sanitation (cesspools)

Containerize infectious wastesPublic health awareness

Monitoring of water qualityOperation amp maintenance planProper design of canals and provision of access for weed and sediments removal

Control of agrochemical use

IAsMunicipality

IAscommunity

IAscommunity

Ministry of Health

Ministry of Energy and Water

IAs community

ContractorIAs

Ministry of Agriculturecommunity

53 Training Program and Capacity Building

40 The MOSA lacks the capacities and the expertise to work in the field of environmental monitoring and protection Moreover it is expected that the IAs mostly CSOs and SDCs do not have the needed resources to undertake the requirements needed in terms of EAs and designing mitigation measures This would require a detailed capacity building program that targets all levels of the decision making process in the project The central team at the MOSA and the PCT need to be oriented to the general approach to environmental safeguards importance use and how that could affect the selection implementation and monitoring of Sub-projects SDFCs and IAs should be trained on

21

the technical aspects of detection and mitigation and how these could be imbedded within the process of project identification to formulation to implementation These safeguards will have to be an integral part of any sub-project proposal and consequently any detailed action plan for any specific sub-project Environmental expertise within the implementing and executing bodies will be strengthened Training programs will designed and implemented with the assistance of a local or international expert and will target levels as stated in the Table 2 page 20

41 PCT and IAs At the initiation of the CSD and prior to bidding and selection of IAs a workshop will be provided and will include an environmental session to raise environmental awareness and to clarify the specific environmental requirements related to design and implementation of the SPPP

42 Another training workshop will be provided to the PCT and selected IAs and will cover the following to IAs

EIA techniques Screening sub-projects for environmental review Use of practical formschecklists Best environmental practices in design and implementation of projects Effective implementation of mitigation measures Project supervision Monitoring and evaluation

43 Local NGOs and Contractors IAs will be required to provide workshops for local NGOs and contractors focusing on public awareness case studies of environmental issues experienced in similar projects use of environmental guidelines and implementation of mitigation measures (Table 2 Annex III)

22

Table 2 Training and Capacity Building Program for Implementing the ESAFTraining

Capacity BuildingParticipating Stakeholders

Skills acquired Scheduling Cost Source

ManagementInstitutional

1year

SPPP manager MOSA central unit Head of concerned

departments at MOSA PCT

Decision making and delegation Work procedures Environmental awareness National guidelines WB guidelines Classification and mitigation

Prior to sub-project preparation Planning phase Refresher every 3 months as we

go along the project

Undertaken by the Environmental

SpecialistMiscellaneous

7500 USD

WBMOSA

Institutional at Intermediate levels

2 training sessions of 2 days year

(for SDC and IA X5 regions)

PCT Emanating committee SDC managers IAs

Environmental and social policies

Laws and regulations GOL and WB safeguards Evaluation and selection

During sub-project preparation Planning phase Sub-project evaluation

Undertaken by the Environmental

SpecialistMiscellaneous

30000 USD

WB MOSA

Implementation1 day session X2 year X 5 regions

IAs SDC staff Beneficiaries Municipalities

Environment and social tools Screening amp monitoring

methods Sustainability of the process Practical mitigation and

safeguards

During sub-project preparation Mobilization Implementation

Undertaken by the Environmental

SpecialistMiscellaneous

50000 USD

WB MOSA

Monitoring Evaluation and

Reporting1 dayX2 year X5

regions

IAs SDC staff Beneficiaries

Municipalities

Environmental and social monitoring and compliance

Progress report preparation Monitoring and Evaluation

During sub-project preparation MobilizationImplementation

Environmental Specialist + consultant

50000 USD

WB MOSA

Total 137500 USD (includes in kind contribution from MOSA)

23

54 Environmental Monitoring

44 Environmental Monitoring will be the responsibility of the ES PCT and MOSA Central Unit with the supervision of the LCP and will include compliance monitoring during implementation and also monitoring of significant impacts during the operation of the subproject

Table 3 Typical Examples of Monitoring Plan for the Operation of Different Subprojects

Sub-project Monitoring Indicators Responsibility FrequencyRoads rehabilitation

Operating drainage channels

NGOs in close coordination with local community

Semi-annual assessment

Improvements to Water Supply and Sanitation Facilities

Irrigation and drainage

Distribution network without leaksNo leakage or overflows of manholes or drainsWater Quality Monitoring

Irrigation network without leaksDrainage channels clean and properly maintainedWater quality parameters (pH COD BOD SS)

NGOs in close coordination with local community

Ministry of Health and Ministry of Energy and Water

NGOs in close coordination with local community

Testing by Ministry of Health and Ministry of Energy and Water

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Rehabilitation of schools

Rehabilitation of health clinics

Toilet facilities clean and functioning properlyDrinking water faucets clean and safe from contamination

NGOs in close coordination with local community and appropriate municipality

Ministry of Health in close coordination with local community

Semi-annual assessment

Semi-annual assessment

23

24

45 The Environmental Specialist (ES) of the PCT will also conduct periodic monitoring by visiting the sites of the various sub-projects at least twice during the implementation period of the sub-project

46 Monitoring indicators shall be developed for both the mobilization and the operation phase of the subprojects Monitoring of activities will have to ensure that mitigation measures of operations impacts are being implemented properly while the monitoring of operation is to ensure that no unforeseen negative impacts are arising

55 Sub-project Cycle

47 Component 2 of the SPPP is the Community Social Development Program (CSD) which will be financing community-based sub-projects through grants The Program will have two windows one for social services whereas the other is for Income Generation Activities (IGA) support with the review and approval mechanisms in large part being the same for both windows While Component 3 focuses on Poverty Targeting thus the services provided will have no impact on the environment component 1 will focus on the provision of technology and training to SDCs

48 Applicants will be invited to use standard forms (available on the MOSA website and upon request from SDCs) to submit proposals to the relevant SDC in cases where the applicant is the SDC itself the application will be submitted directly to the CSD program team in Beirut

49 SDCs will immediately check all proposals for completeness and give a receipt to the applicant with a proposal number proposals found to be incomplete will be rejected with an explanation All complete proposals will be presented for discussion to the relevant Local Community Platform (LCP) or equivalent consultative body to obtain feedback on among other things the actual need (in case of social services) or likely market value (in the case of IGA) of the proposed activity the reputation of the applicant the likely sustainability of the proposed activity the preliminary classification of the project within environmental categories (the final classification will be pending on the decision of the environmental specialist within the PCT) any problematic aspect (conflict of interest etc) and the overall compliance of the proposal with the purposes of the program This feedback is not binding but will be taken into consideration when deciding whether or not to fund the proposal The CSD program team will carry out a detailed desk review of all complete proposals to assess their technical quality as well as the budget and time line suggested for the sub-project The environmental specialist member of the Project Coordinating Team (PCT) will review the proposal and prepare all needed documentation based on his classification of the sub-project

56 Screening of Sub-Projects

50 Each sub-project to be implemented by an IA will be subjected to an environmental screening Using the screening form (Form 1) environmental and social checklists for the proposed sub-projects will be screened by the environmental specialist to identify any potential adverse impacts

25

From an environmental standpoint the screening form may identify impacts form sub-projects the issue of solid waste disposal at the site of a sub-project may come out as a point to look at in terms of designing mitigation measures to avoid negative impacts The selection of adequate storage collection and proper disposal could be steps to consider carefully

57 The Environmental and Social Screening Process

51 The objectives of sub-project screening is to determine which activities are likely to have negative environmental and social impacts

571 Subproject Screening Procedures

52 The sub-projects funded under this project are generally categorized as Category B or C and screening mechanisms would ensure that any identified Category A sub-projects are not funded under the project Due to the fact that most Category B sub-projects are small-scale which do not result in adverse negative environmental impacts this will require an ESMP which has clear due diligence environmental and social procedures (including the setting out of institutional responsibilities timing and budget) for sub-projects The ESMP should take into consideration the applicable requirements under the Bankrsquos ten safeguard policies

572 Environmental Sub-Project Screening Checklistsforms

53 The Operation Manual (OM) should contain for each type of sub-project a simple environmental screening checklist (Form 1)) which poses a series of questions designed to identify risks to the environment The goal of the checklist (also called a screening or environmental data sheet) is to identify which sub-projects require more environmental information in the form of a site-specific ESMP or which can proceed without any special mitigation measures that is falling under category C

Form 1 Environmental Screening Check-list

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

18

32 The implementation of the SPPP falls under the responsibility of MOSA who would be in charge of coordinating the various activities through its Social Development Centers (SDCs) with concerned local governments and NGOs A Project Coordination Team (PCT) will be established and would comprise experts with relevant experience in implementing similar projects and with proven capacity to handle all functions required in such a project Among its mandates the PCT will ensure that any sponsored subproject is environmentally sound and sustainable

33 The PCT shall ensure the following

Environmental considerations will be included as criteria for selecting activities to be supported by the project environmental assessment would become an integral part of the project cycle of any subproject

Environmental guidelines are followed and used throughout the project cycle

Environmental issues are introduced to beneficiaries through education and promotion of environmentally beneficial subprojects

34 The execution of the CSD will be undertaken by Civil Society Organizations (CSO) who would consist of qualified local authorities or national NGOs with strong community ties and proven execution capacity The SDC would assist local NGOs LCF and communities in identifying local needs preparing subprojects coordinating with concerned ministries and implementing the subprojects

42 Environmental Assessment (EA)

35 The World Bank Operational Policy (OP 401) on Environmental Assessment (January 1999) defines the Bankrsquos environmental assessment requirements to ensure that funded sub-projects are environmentally sound and sustainable A screening process is undertaken for all funded sub-projects to assess the magnitude and adversity of predicted environmental impacts and to determine the appropriate extent and type of EA Depending on the type location sensitivity and scale of the project as well as the nature and magnitude of environmental impacts sub-projects are classified into one of three categories

(a)- Category A Sub-Projects that are likely to cause significant and possibly irremediable environmental impacts

(b)- Category B Sub-Projects that might cause lesser adverse impacts than those of Category A and the impacts are often remediable or could be mitigated for

(c)- Category C Sub-Projects which could have minimal or no adverse environmental impacts

19

36 The SPPP will only fund sub-projects that can be classified as either Category B or Category C only For instance all income enhancement sub-projects will be classified as Category C while most social sub-projects will be Category B Sub-projects that are likely to cause substantial negative impacts and are expected to fall in Category A will not be approved for funding

37 This document will provide guidance with respect to the preparation of environmental assessment for the various funded subprojects These guidelines are based on the World Bank Operational Policies (OP 401) the Environmental Assessment Source book (1991) and its updates in addition to the Decree 86332012 on EA issued by the GOL

5 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

51 Objectives and Structure of the ESMP

38 The objectives of the ESMP are to mitigate the adverse environmental impacts identified in the SPPP The ESMP will consist of three kinds of activities

o Implementation of mitigation measures o Strengthening the capacities of PCT SDCs and local NGOs o Monitoring and evaluation of mitigation measures identified during subproject

formulation or within the environmental assessment report

52 Implementation of Mitigation Measures

39 Mitigation measures identified (Table 1) are for typical sub-projects and MOSAPCT will ensure that such measures are adhered to during the overall implementation of the SPPP

Table 1 Potential Environmental Impacts and Proposed Mitigation Measures for Different Subprojects

Project Component

Potential Impacts Mitigation Measures Responsibility

Roads rehabilitation

Clogging of natural drainage channelsEncroachment on private property

Dumping of construction wastes and accidental spills of machine fuels etcRisk of damage to unknown archaeological sites

Maintain ditches

Detailed property boundary surveys and flagging in fieldProper disposal of construction wastes

Use ldquochance findrdquo procedures and coordinate with appropriate

Contractor

ContractorIA

Contractor

IAsArcheology department

20

government agency

Rehabilitation of schools

Rehabilitation of health clinics

Irrigation and drainage

Improper disposal of wastes

Water quality degradation in ponds and reservoirsClogging of canals from weedssedimentsInefficient water flow because of heavy sedimentation

Degradation of water systems receiving irrigation waters by nutrients agrochemical and salts

Proper disposal of solid wastesPriority given to rehabilitation of toiletsInstallation of sanitation (cesspools)

Containerize infectious wastesPublic health awareness

Monitoring of water qualityOperation amp maintenance planProper design of canals and provision of access for weed and sediments removal

Control of agrochemical use

IAsMunicipality

IAscommunity

IAscommunity

Ministry of Health

Ministry of Energy and Water

IAs community

ContractorIAs

Ministry of Agriculturecommunity

53 Training Program and Capacity Building

40 The MOSA lacks the capacities and the expertise to work in the field of environmental monitoring and protection Moreover it is expected that the IAs mostly CSOs and SDCs do not have the needed resources to undertake the requirements needed in terms of EAs and designing mitigation measures This would require a detailed capacity building program that targets all levels of the decision making process in the project The central team at the MOSA and the PCT need to be oriented to the general approach to environmental safeguards importance use and how that could affect the selection implementation and monitoring of Sub-projects SDFCs and IAs should be trained on

21

the technical aspects of detection and mitigation and how these could be imbedded within the process of project identification to formulation to implementation These safeguards will have to be an integral part of any sub-project proposal and consequently any detailed action plan for any specific sub-project Environmental expertise within the implementing and executing bodies will be strengthened Training programs will designed and implemented with the assistance of a local or international expert and will target levels as stated in the Table 2 page 20

41 PCT and IAs At the initiation of the CSD and prior to bidding and selection of IAs a workshop will be provided and will include an environmental session to raise environmental awareness and to clarify the specific environmental requirements related to design and implementation of the SPPP

42 Another training workshop will be provided to the PCT and selected IAs and will cover the following to IAs

EIA techniques Screening sub-projects for environmental review Use of practical formschecklists Best environmental practices in design and implementation of projects Effective implementation of mitigation measures Project supervision Monitoring and evaluation

43 Local NGOs and Contractors IAs will be required to provide workshops for local NGOs and contractors focusing on public awareness case studies of environmental issues experienced in similar projects use of environmental guidelines and implementation of mitigation measures (Table 2 Annex III)

22

Table 2 Training and Capacity Building Program for Implementing the ESAFTraining

Capacity BuildingParticipating Stakeholders

Skills acquired Scheduling Cost Source

ManagementInstitutional

1year

SPPP manager MOSA central unit Head of concerned

departments at MOSA PCT

Decision making and delegation Work procedures Environmental awareness National guidelines WB guidelines Classification and mitigation

Prior to sub-project preparation Planning phase Refresher every 3 months as we

go along the project

Undertaken by the Environmental

SpecialistMiscellaneous

7500 USD

WBMOSA

Institutional at Intermediate levels

2 training sessions of 2 days year

(for SDC and IA X5 regions)

PCT Emanating committee SDC managers IAs

Environmental and social policies

Laws and regulations GOL and WB safeguards Evaluation and selection

During sub-project preparation Planning phase Sub-project evaluation

Undertaken by the Environmental

SpecialistMiscellaneous

30000 USD

WB MOSA

Implementation1 day session X2 year X 5 regions

IAs SDC staff Beneficiaries Municipalities

Environment and social tools Screening amp monitoring

methods Sustainability of the process Practical mitigation and

safeguards

During sub-project preparation Mobilization Implementation

Undertaken by the Environmental

SpecialistMiscellaneous

50000 USD

WB MOSA

Monitoring Evaluation and

Reporting1 dayX2 year X5

regions

IAs SDC staff Beneficiaries

Municipalities

Environmental and social monitoring and compliance

Progress report preparation Monitoring and Evaluation

During sub-project preparation MobilizationImplementation

Environmental Specialist + consultant

50000 USD

WB MOSA

Total 137500 USD (includes in kind contribution from MOSA)

23

54 Environmental Monitoring

44 Environmental Monitoring will be the responsibility of the ES PCT and MOSA Central Unit with the supervision of the LCP and will include compliance monitoring during implementation and also monitoring of significant impacts during the operation of the subproject

Table 3 Typical Examples of Monitoring Plan for the Operation of Different Subprojects

Sub-project Monitoring Indicators Responsibility FrequencyRoads rehabilitation

Operating drainage channels

NGOs in close coordination with local community

Semi-annual assessment

Improvements to Water Supply and Sanitation Facilities

Irrigation and drainage

Distribution network without leaksNo leakage or overflows of manholes or drainsWater Quality Monitoring

Irrigation network without leaksDrainage channels clean and properly maintainedWater quality parameters (pH COD BOD SS)

NGOs in close coordination with local community

Ministry of Health and Ministry of Energy and Water

NGOs in close coordination with local community

Testing by Ministry of Health and Ministry of Energy and Water

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Rehabilitation of schools

Rehabilitation of health clinics

Toilet facilities clean and functioning properlyDrinking water faucets clean and safe from contamination

NGOs in close coordination with local community and appropriate municipality

Ministry of Health in close coordination with local community

Semi-annual assessment

Semi-annual assessment

23

24

45 The Environmental Specialist (ES) of the PCT will also conduct periodic monitoring by visiting the sites of the various sub-projects at least twice during the implementation period of the sub-project

46 Monitoring indicators shall be developed for both the mobilization and the operation phase of the subprojects Monitoring of activities will have to ensure that mitigation measures of operations impacts are being implemented properly while the monitoring of operation is to ensure that no unforeseen negative impacts are arising

55 Sub-project Cycle

47 Component 2 of the SPPP is the Community Social Development Program (CSD) which will be financing community-based sub-projects through grants The Program will have two windows one for social services whereas the other is for Income Generation Activities (IGA) support with the review and approval mechanisms in large part being the same for both windows While Component 3 focuses on Poverty Targeting thus the services provided will have no impact on the environment component 1 will focus on the provision of technology and training to SDCs

48 Applicants will be invited to use standard forms (available on the MOSA website and upon request from SDCs) to submit proposals to the relevant SDC in cases where the applicant is the SDC itself the application will be submitted directly to the CSD program team in Beirut

49 SDCs will immediately check all proposals for completeness and give a receipt to the applicant with a proposal number proposals found to be incomplete will be rejected with an explanation All complete proposals will be presented for discussion to the relevant Local Community Platform (LCP) or equivalent consultative body to obtain feedback on among other things the actual need (in case of social services) or likely market value (in the case of IGA) of the proposed activity the reputation of the applicant the likely sustainability of the proposed activity the preliminary classification of the project within environmental categories (the final classification will be pending on the decision of the environmental specialist within the PCT) any problematic aspect (conflict of interest etc) and the overall compliance of the proposal with the purposes of the program This feedback is not binding but will be taken into consideration when deciding whether or not to fund the proposal The CSD program team will carry out a detailed desk review of all complete proposals to assess their technical quality as well as the budget and time line suggested for the sub-project The environmental specialist member of the Project Coordinating Team (PCT) will review the proposal and prepare all needed documentation based on his classification of the sub-project

56 Screening of Sub-Projects

50 Each sub-project to be implemented by an IA will be subjected to an environmental screening Using the screening form (Form 1) environmental and social checklists for the proposed sub-projects will be screened by the environmental specialist to identify any potential adverse impacts

25

From an environmental standpoint the screening form may identify impacts form sub-projects the issue of solid waste disposal at the site of a sub-project may come out as a point to look at in terms of designing mitigation measures to avoid negative impacts The selection of adequate storage collection and proper disposal could be steps to consider carefully

57 The Environmental and Social Screening Process

51 The objectives of sub-project screening is to determine which activities are likely to have negative environmental and social impacts

571 Subproject Screening Procedures

52 The sub-projects funded under this project are generally categorized as Category B or C and screening mechanisms would ensure that any identified Category A sub-projects are not funded under the project Due to the fact that most Category B sub-projects are small-scale which do not result in adverse negative environmental impacts this will require an ESMP which has clear due diligence environmental and social procedures (including the setting out of institutional responsibilities timing and budget) for sub-projects The ESMP should take into consideration the applicable requirements under the Bankrsquos ten safeguard policies

572 Environmental Sub-Project Screening Checklistsforms

53 The Operation Manual (OM) should contain for each type of sub-project a simple environmental screening checklist (Form 1)) which poses a series of questions designed to identify risks to the environment The goal of the checklist (also called a screening or environmental data sheet) is to identify which sub-projects require more environmental information in the form of a site-specific ESMP or which can proceed without any special mitigation measures that is falling under category C

Form 1 Environmental Screening Check-list

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

19

36 The SPPP will only fund sub-projects that can be classified as either Category B or Category C only For instance all income enhancement sub-projects will be classified as Category C while most social sub-projects will be Category B Sub-projects that are likely to cause substantial negative impacts and are expected to fall in Category A will not be approved for funding

37 This document will provide guidance with respect to the preparation of environmental assessment for the various funded subprojects These guidelines are based on the World Bank Operational Policies (OP 401) the Environmental Assessment Source book (1991) and its updates in addition to the Decree 86332012 on EA issued by the GOL

5 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

51 Objectives and Structure of the ESMP

38 The objectives of the ESMP are to mitigate the adverse environmental impacts identified in the SPPP The ESMP will consist of three kinds of activities

o Implementation of mitigation measures o Strengthening the capacities of PCT SDCs and local NGOs o Monitoring and evaluation of mitigation measures identified during subproject

formulation or within the environmental assessment report

52 Implementation of Mitigation Measures

39 Mitigation measures identified (Table 1) are for typical sub-projects and MOSAPCT will ensure that such measures are adhered to during the overall implementation of the SPPP

Table 1 Potential Environmental Impacts and Proposed Mitigation Measures for Different Subprojects

Project Component

Potential Impacts Mitigation Measures Responsibility

Roads rehabilitation

Clogging of natural drainage channelsEncroachment on private property

Dumping of construction wastes and accidental spills of machine fuels etcRisk of damage to unknown archaeological sites

Maintain ditches

Detailed property boundary surveys and flagging in fieldProper disposal of construction wastes

Use ldquochance findrdquo procedures and coordinate with appropriate

Contractor

ContractorIA

Contractor

IAsArcheology department

20

government agency

Rehabilitation of schools

Rehabilitation of health clinics

Irrigation and drainage

Improper disposal of wastes

Water quality degradation in ponds and reservoirsClogging of canals from weedssedimentsInefficient water flow because of heavy sedimentation

Degradation of water systems receiving irrigation waters by nutrients agrochemical and salts

Proper disposal of solid wastesPriority given to rehabilitation of toiletsInstallation of sanitation (cesspools)

Containerize infectious wastesPublic health awareness

Monitoring of water qualityOperation amp maintenance planProper design of canals and provision of access for weed and sediments removal

Control of agrochemical use

IAsMunicipality

IAscommunity

IAscommunity

Ministry of Health

Ministry of Energy and Water

IAs community

ContractorIAs

Ministry of Agriculturecommunity

53 Training Program and Capacity Building

40 The MOSA lacks the capacities and the expertise to work in the field of environmental monitoring and protection Moreover it is expected that the IAs mostly CSOs and SDCs do not have the needed resources to undertake the requirements needed in terms of EAs and designing mitigation measures This would require a detailed capacity building program that targets all levels of the decision making process in the project The central team at the MOSA and the PCT need to be oriented to the general approach to environmental safeguards importance use and how that could affect the selection implementation and monitoring of Sub-projects SDFCs and IAs should be trained on

21

the technical aspects of detection and mitigation and how these could be imbedded within the process of project identification to formulation to implementation These safeguards will have to be an integral part of any sub-project proposal and consequently any detailed action plan for any specific sub-project Environmental expertise within the implementing and executing bodies will be strengthened Training programs will designed and implemented with the assistance of a local or international expert and will target levels as stated in the Table 2 page 20

41 PCT and IAs At the initiation of the CSD and prior to bidding and selection of IAs a workshop will be provided and will include an environmental session to raise environmental awareness and to clarify the specific environmental requirements related to design and implementation of the SPPP

42 Another training workshop will be provided to the PCT and selected IAs and will cover the following to IAs

EIA techniques Screening sub-projects for environmental review Use of practical formschecklists Best environmental practices in design and implementation of projects Effective implementation of mitigation measures Project supervision Monitoring and evaluation

43 Local NGOs and Contractors IAs will be required to provide workshops for local NGOs and contractors focusing on public awareness case studies of environmental issues experienced in similar projects use of environmental guidelines and implementation of mitigation measures (Table 2 Annex III)

22

Table 2 Training and Capacity Building Program for Implementing the ESAFTraining

Capacity BuildingParticipating Stakeholders

Skills acquired Scheduling Cost Source

ManagementInstitutional

1year

SPPP manager MOSA central unit Head of concerned

departments at MOSA PCT

Decision making and delegation Work procedures Environmental awareness National guidelines WB guidelines Classification and mitigation

Prior to sub-project preparation Planning phase Refresher every 3 months as we

go along the project

Undertaken by the Environmental

SpecialistMiscellaneous

7500 USD

WBMOSA

Institutional at Intermediate levels

2 training sessions of 2 days year

(for SDC and IA X5 regions)

PCT Emanating committee SDC managers IAs

Environmental and social policies

Laws and regulations GOL and WB safeguards Evaluation and selection

During sub-project preparation Planning phase Sub-project evaluation

Undertaken by the Environmental

SpecialistMiscellaneous

30000 USD

WB MOSA

Implementation1 day session X2 year X 5 regions

IAs SDC staff Beneficiaries Municipalities

Environment and social tools Screening amp monitoring

methods Sustainability of the process Practical mitigation and

safeguards

During sub-project preparation Mobilization Implementation

Undertaken by the Environmental

SpecialistMiscellaneous

50000 USD

WB MOSA

Monitoring Evaluation and

Reporting1 dayX2 year X5

regions

IAs SDC staff Beneficiaries

Municipalities

Environmental and social monitoring and compliance

Progress report preparation Monitoring and Evaluation

During sub-project preparation MobilizationImplementation

Environmental Specialist + consultant

50000 USD

WB MOSA

Total 137500 USD (includes in kind contribution from MOSA)

23

54 Environmental Monitoring

44 Environmental Monitoring will be the responsibility of the ES PCT and MOSA Central Unit with the supervision of the LCP and will include compliance monitoring during implementation and also monitoring of significant impacts during the operation of the subproject

Table 3 Typical Examples of Monitoring Plan for the Operation of Different Subprojects

Sub-project Monitoring Indicators Responsibility FrequencyRoads rehabilitation

Operating drainage channels

NGOs in close coordination with local community

Semi-annual assessment

Improvements to Water Supply and Sanitation Facilities

Irrigation and drainage

Distribution network without leaksNo leakage or overflows of manholes or drainsWater Quality Monitoring

Irrigation network without leaksDrainage channels clean and properly maintainedWater quality parameters (pH COD BOD SS)

NGOs in close coordination with local community

Ministry of Health and Ministry of Energy and Water

NGOs in close coordination with local community

Testing by Ministry of Health and Ministry of Energy and Water

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Rehabilitation of schools

Rehabilitation of health clinics

Toilet facilities clean and functioning properlyDrinking water faucets clean and safe from contamination

NGOs in close coordination with local community and appropriate municipality

Ministry of Health in close coordination with local community

Semi-annual assessment

Semi-annual assessment

23

24

45 The Environmental Specialist (ES) of the PCT will also conduct periodic monitoring by visiting the sites of the various sub-projects at least twice during the implementation period of the sub-project

46 Monitoring indicators shall be developed for both the mobilization and the operation phase of the subprojects Monitoring of activities will have to ensure that mitigation measures of operations impacts are being implemented properly while the monitoring of operation is to ensure that no unforeseen negative impacts are arising

55 Sub-project Cycle

47 Component 2 of the SPPP is the Community Social Development Program (CSD) which will be financing community-based sub-projects through grants The Program will have two windows one for social services whereas the other is for Income Generation Activities (IGA) support with the review and approval mechanisms in large part being the same for both windows While Component 3 focuses on Poverty Targeting thus the services provided will have no impact on the environment component 1 will focus on the provision of technology and training to SDCs

48 Applicants will be invited to use standard forms (available on the MOSA website and upon request from SDCs) to submit proposals to the relevant SDC in cases where the applicant is the SDC itself the application will be submitted directly to the CSD program team in Beirut

49 SDCs will immediately check all proposals for completeness and give a receipt to the applicant with a proposal number proposals found to be incomplete will be rejected with an explanation All complete proposals will be presented for discussion to the relevant Local Community Platform (LCP) or equivalent consultative body to obtain feedback on among other things the actual need (in case of social services) or likely market value (in the case of IGA) of the proposed activity the reputation of the applicant the likely sustainability of the proposed activity the preliminary classification of the project within environmental categories (the final classification will be pending on the decision of the environmental specialist within the PCT) any problematic aspect (conflict of interest etc) and the overall compliance of the proposal with the purposes of the program This feedback is not binding but will be taken into consideration when deciding whether or not to fund the proposal The CSD program team will carry out a detailed desk review of all complete proposals to assess their technical quality as well as the budget and time line suggested for the sub-project The environmental specialist member of the Project Coordinating Team (PCT) will review the proposal and prepare all needed documentation based on his classification of the sub-project

56 Screening of Sub-Projects

50 Each sub-project to be implemented by an IA will be subjected to an environmental screening Using the screening form (Form 1) environmental and social checklists for the proposed sub-projects will be screened by the environmental specialist to identify any potential adverse impacts

25

From an environmental standpoint the screening form may identify impacts form sub-projects the issue of solid waste disposal at the site of a sub-project may come out as a point to look at in terms of designing mitigation measures to avoid negative impacts The selection of adequate storage collection and proper disposal could be steps to consider carefully

57 The Environmental and Social Screening Process

51 The objectives of sub-project screening is to determine which activities are likely to have negative environmental and social impacts

571 Subproject Screening Procedures

52 The sub-projects funded under this project are generally categorized as Category B or C and screening mechanisms would ensure that any identified Category A sub-projects are not funded under the project Due to the fact that most Category B sub-projects are small-scale which do not result in adverse negative environmental impacts this will require an ESMP which has clear due diligence environmental and social procedures (including the setting out of institutional responsibilities timing and budget) for sub-projects The ESMP should take into consideration the applicable requirements under the Bankrsquos ten safeguard policies

572 Environmental Sub-Project Screening Checklistsforms

53 The Operation Manual (OM) should contain for each type of sub-project a simple environmental screening checklist (Form 1)) which poses a series of questions designed to identify risks to the environment The goal of the checklist (also called a screening or environmental data sheet) is to identify which sub-projects require more environmental information in the form of a site-specific ESMP or which can proceed without any special mitigation measures that is falling under category C

Form 1 Environmental Screening Check-list

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

20

government agency

Rehabilitation of schools

Rehabilitation of health clinics

Irrigation and drainage

Improper disposal of wastes

Water quality degradation in ponds and reservoirsClogging of canals from weedssedimentsInefficient water flow because of heavy sedimentation

Degradation of water systems receiving irrigation waters by nutrients agrochemical and salts

Proper disposal of solid wastesPriority given to rehabilitation of toiletsInstallation of sanitation (cesspools)

Containerize infectious wastesPublic health awareness

Monitoring of water qualityOperation amp maintenance planProper design of canals and provision of access for weed and sediments removal

Control of agrochemical use

IAsMunicipality

IAscommunity

IAscommunity

Ministry of Health

Ministry of Energy and Water

IAs community

ContractorIAs

Ministry of Agriculturecommunity

53 Training Program and Capacity Building

40 The MOSA lacks the capacities and the expertise to work in the field of environmental monitoring and protection Moreover it is expected that the IAs mostly CSOs and SDCs do not have the needed resources to undertake the requirements needed in terms of EAs and designing mitigation measures This would require a detailed capacity building program that targets all levels of the decision making process in the project The central team at the MOSA and the PCT need to be oriented to the general approach to environmental safeguards importance use and how that could affect the selection implementation and monitoring of Sub-projects SDFCs and IAs should be trained on

21

the technical aspects of detection and mitigation and how these could be imbedded within the process of project identification to formulation to implementation These safeguards will have to be an integral part of any sub-project proposal and consequently any detailed action plan for any specific sub-project Environmental expertise within the implementing and executing bodies will be strengthened Training programs will designed and implemented with the assistance of a local or international expert and will target levels as stated in the Table 2 page 20

41 PCT and IAs At the initiation of the CSD and prior to bidding and selection of IAs a workshop will be provided and will include an environmental session to raise environmental awareness and to clarify the specific environmental requirements related to design and implementation of the SPPP

42 Another training workshop will be provided to the PCT and selected IAs and will cover the following to IAs

EIA techniques Screening sub-projects for environmental review Use of practical formschecklists Best environmental practices in design and implementation of projects Effective implementation of mitigation measures Project supervision Monitoring and evaluation

43 Local NGOs and Contractors IAs will be required to provide workshops for local NGOs and contractors focusing on public awareness case studies of environmental issues experienced in similar projects use of environmental guidelines and implementation of mitigation measures (Table 2 Annex III)

22

Table 2 Training and Capacity Building Program for Implementing the ESAFTraining

Capacity BuildingParticipating Stakeholders

Skills acquired Scheduling Cost Source

ManagementInstitutional

1year

SPPP manager MOSA central unit Head of concerned

departments at MOSA PCT

Decision making and delegation Work procedures Environmental awareness National guidelines WB guidelines Classification and mitigation

Prior to sub-project preparation Planning phase Refresher every 3 months as we

go along the project

Undertaken by the Environmental

SpecialistMiscellaneous

7500 USD

WBMOSA

Institutional at Intermediate levels

2 training sessions of 2 days year

(for SDC and IA X5 regions)

PCT Emanating committee SDC managers IAs

Environmental and social policies

Laws and regulations GOL and WB safeguards Evaluation and selection

During sub-project preparation Planning phase Sub-project evaluation

Undertaken by the Environmental

SpecialistMiscellaneous

30000 USD

WB MOSA

Implementation1 day session X2 year X 5 regions

IAs SDC staff Beneficiaries Municipalities

Environment and social tools Screening amp monitoring

methods Sustainability of the process Practical mitigation and

safeguards

During sub-project preparation Mobilization Implementation

Undertaken by the Environmental

SpecialistMiscellaneous

50000 USD

WB MOSA

Monitoring Evaluation and

Reporting1 dayX2 year X5

regions

IAs SDC staff Beneficiaries

Municipalities

Environmental and social monitoring and compliance

Progress report preparation Monitoring and Evaluation

During sub-project preparation MobilizationImplementation

Environmental Specialist + consultant

50000 USD

WB MOSA

Total 137500 USD (includes in kind contribution from MOSA)

23

54 Environmental Monitoring

44 Environmental Monitoring will be the responsibility of the ES PCT and MOSA Central Unit with the supervision of the LCP and will include compliance monitoring during implementation and also monitoring of significant impacts during the operation of the subproject

Table 3 Typical Examples of Monitoring Plan for the Operation of Different Subprojects

Sub-project Monitoring Indicators Responsibility FrequencyRoads rehabilitation

Operating drainage channels

NGOs in close coordination with local community

Semi-annual assessment

Improvements to Water Supply and Sanitation Facilities

Irrigation and drainage

Distribution network without leaksNo leakage or overflows of manholes or drainsWater Quality Monitoring

Irrigation network without leaksDrainage channels clean and properly maintainedWater quality parameters (pH COD BOD SS)

NGOs in close coordination with local community

Ministry of Health and Ministry of Energy and Water

NGOs in close coordination with local community

Testing by Ministry of Health and Ministry of Energy and Water

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Rehabilitation of schools

Rehabilitation of health clinics

Toilet facilities clean and functioning properlyDrinking water faucets clean and safe from contamination

NGOs in close coordination with local community and appropriate municipality

Ministry of Health in close coordination with local community

Semi-annual assessment

Semi-annual assessment

23

24

45 The Environmental Specialist (ES) of the PCT will also conduct periodic monitoring by visiting the sites of the various sub-projects at least twice during the implementation period of the sub-project

46 Monitoring indicators shall be developed for both the mobilization and the operation phase of the subprojects Monitoring of activities will have to ensure that mitigation measures of operations impacts are being implemented properly while the monitoring of operation is to ensure that no unforeseen negative impacts are arising

55 Sub-project Cycle

47 Component 2 of the SPPP is the Community Social Development Program (CSD) which will be financing community-based sub-projects through grants The Program will have two windows one for social services whereas the other is for Income Generation Activities (IGA) support with the review and approval mechanisms in large part being the same for both windows While Component 3 focuses on Poverty Targeting thus the services provided will have no impact on the environment component 1 will focus on the provision of technology and training to SDCs

48 Applicants will be invited to use standard forms (available on the MOSA website and upon request from SDCs) to submit proposals to the relevant SDC in cases where the applicant is the SDC itself the application will be submitted directly to the CSD program team in Beirut

49 SDCs will immediately check all proposals for completeness and give a receipt to the applicant with a proposal number proposals found to be incomplete will be rejected with an explanation All complete proposals will be presented for discussion to the relevant Local Community Platform (LCP) or equivalent consultative body to obtain feedback on among other things the actual need (in case of social services) or likely market value (in the case of IGA) of the proposed activity the reputation of the applicant the likely sustainability of the proposed activity the preliminary classification of the project within environmental categories (the final classification will be pending on the decision of the environmental specialist within the PCT) any problematic aspect (conflict of interest etc) and the overall compliance of the proposal with the purposes of the program This feedback is not binding but will be taken into consideration when deciding whether or not to fund the proposal The CSD program team will carry out a detailed desk review of all complete proposals to assess their technical quality as well as the budget and time line suggested for the sub-project The environmental specialist member of the Project Coordinating Team (PCT) will review the proposal and prepare all needed documentation based on his classification of the sub-project

56 Screening of Sub-Projects

50 Each sub-project to be implemented by an IA will be subjected to an environmental screening Using the screening form (Form 1) environmental and social checklists for the proposed sub-projects will be screened by the environmental specialist to identify any potential adverse impacts

25

From an environmental standpoint the screening form may identify impacts form sub-projects the issue of solid waste disposal at the site of a sub-project may come out as a point to look at in terms of designing mitigation measures to avoid negative impacts The selection of adequate storage collection and proper disposal could be steps to consider carefully

57 The Environmental and Social Screening Process

51 The objectives of sub-project screening is to determine which activities are likely to have negative environmental and social impacts

571 Subproject Screening Procedures

52 The sub-projects funded under this project are generally categorized as Category B or C and screening mechanisms would ensure that any identified Category A sub-projects are not funded under the project Due to the fact that most Category B sub-projects are small-scale which do not result in adverse negative environmental impacts this will require an ESMP which has clear due diligence environmental and social procedures (including the setting out of institutional responsibilities timing and budget) for sub-projects The ESMP should take into consideration the applicable requirements under the Bankrsquos ten safeguard policies

572 Environmental Sub-Project Screening Checklistsforms

53 The Operation Manual (OM) should contain for each type of sub-project a simple environmental screening checklist (Form 1)) which poses a series of questions designed to identify risks to the environment The goal of the checklist (also called a screening or environmental data sheet) is to identify which sub-projects require more environmental information in the form of a site-specific ESMP or which can proceed without any special mitigation measures that is falling under category C

Form 1 Environmental Screening Check-list

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

21

the technical aspects of detection and mitigation and how these could be imbedded within the process of project identification to formulation to implementation These safeguards will have to be an integral part of any sub-project proposal and consequently any detailed action plan for any specific sub-project Environmental expertise within the implementing and executing bodies will be strengthened Training programs will designed and implemented with the assistance of a local or international expert and will target levels as stated in the Table 2 page 20

41 PCT and IAs At the initiation of the CSD and prior to bidding and selection of IAs a workshop will be provided and will include an environmental session to raise environmental awareness and to clarify the specific environmental requirements related to design and implementation of the SPPP

42 Another training workshop will be provided to the PCT and selected IAs and will cover the following to IAs

EIA techniques Screening sub-projects for environmental review Use of practical formschecklists Best environmental practices in design and implementation of projects Effective implementation of mitigation measures Project supervision Monitoring and evaluation

43 Local NGOs and Contractors IAs will be required to provide workshops for local NGOs and contractors focusing on public awareness case studies of environmental issues experienced in similar projects use of environmental guidelines and implementation of mitigation measures (Table 2 Annex III)

22

Table 2 Training and Capacity Building Program for Implementing the ESAFTraining

Capacity BuildingParticipating Stakeholders

Skills acquired Scheduling Cost Source

ManagementInstitutional

1year

SPPP manager MOSA central unit Head of concerned

departments at MOSA PCT

Decision making and delegation Work procedures Environmental awareness National guidelines WB guidelines Classification and mitigation

Prior to sub-project preparation Planning phase Refresher every 3 months as we

go along the project

Undertaken by the Environmental

SpecialistMiscellaneous

7500 USD

WBMOSA

Institutional at Intermediate levels

2 training sessions of 2 days year

(for SDC and IA X5 regions)

PCT Emanating committee SDC managers IAs

Environmental and social policies

Laws and regulations GOL and WB safeguards Evaluation and selection

During sub-project preparation Planning phase Sub-project evaluation

Undertaken by the Environmental

SpecialistMiscellaneous

30000 USD

WB MOSA

Implementation1 day session X2 year X 5 regions

IAs SDC staff Beneficiaries Municipalities

Environment and social tools Screening amp monitoring

methods Sustainability of the process Practical mitigation and

safeguards

During sub-project preparation Mobilization Implementation

Undertaken by the Environmental

SpecialistMiscellaneous

50000 USD

WB MOSA

Monitoring Evaluation and

Reporting1 dayX2 year X5

regions

IAs SDC staff Beneficiaries

Municipalities

Environmental and social monitoring and compliance

Progress report preparation Monitoring and Evaluation

During sub-project preparation MobilizationImplementation

Environmental Specialist + consultant

50000 USD

WB MOSA

Total 137500 USD (includes in kind contribution from MOSA)

23

54 Environmental Monitoring

44 Environmental Monitoring will be the responsibility of the ES PCT and MOSA Central Unit with the supervision of the LCP and will include compliance monitoring during implementation and also monitoring of significant impacts during the operation of the subproject

Table 3 Typical Examples of Monitoring Plan for the Operation of Different Subprojects

Sub-project Monitoring Indicators Responsibility FrequencyRoads rehabilitation

Operating drainage channels

NGOs in close coordination with local community

Semi-annual assessment

Improvements to Water Supply and Sanitation Facilities

Irrigation and drainage

Distribution network without leaksNo leakage or overflows of manholes or drainsWater Quality Monitoring

Irrigation network without leaksDrainage channels clean and properly maintainedWater quality parameters (pH COD BOD SS)

NGOs in close coordination with local community

Ministry of Health and Ministry of Energy and Water

NGOs in close coordination with local community

Testing by Ministry of Health and Ministry of Energy and Water

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Rehabilitation of schools

Rehabilitation of health clinics

Toilet facilities clean and functioning properlyDrinking water faucets clean and safe from contamination

NGOs in close coordination with local community and appropriate municipality

Ministry of Health in close coordination with local community

Semi-annual assessment

Semi-annual assessment

23

24

45 The Environmental Specialist (ES) of the PCT will also conduct periodic monitoring by visiting the sites of the various sub-projects at least twice during the implementation period of the sub-project

46 Monitoring indicators shall be developed for both the mobilization and the operation phase of the subprojects Monitoring of activities will have to ensure that mitigation measures of operations impacts are being implemented properly while the monitoring of operation is to ensure that no unforeseen negative impacts are arising

55 Sub-project Cycle

47 Component 2 of the SPPP is the Community Social Development Program (CSD) which will be financing community-based sub-projects through grants The Program will have two windows one for social services whereas the other is for Income Generation Activities (IGA) support with the review and approval mechanisms in large part being the same for both windows While Component 3 focuses on Poverty Targeting thus the services provided will have no impact on the environment component 1 will focus on the provision of technology and training to SDCs

48 Applicants will be invited to use standard forms (available on the MOSA website and upon request from SDCs) to submit proposals to the relevant SDC in cases where the applicant is the SDC itself the application will be submitted directly to the CSD program team in Beirut

49 SDCs will immediately check all proposals for completeness and give a receipt to the applicant with a proposal number proposals found to be incomplete will be rejected with an explanation All complete proposals will be presented for discussion to the relevant Local Community Platform (LCP) or equivalent consultative body to obtain feedback on among other things the actual need (in case of social services) or likely market value (in the case of IGA) of the proposed activity the reputation of the applicant the likely sustainability of the proposed activity the preliminary classification of the project within environmental categories (the final classification will be pending on the decision of the environmental specialist within the PCT) any problematic aspect (conflict of interest etc) and the overall compliance of the proposal with the purposes of the program This feedback is not binding but will be taken into consideration when deciding whether or not to fund the proposal The CSD program team will carry out a detailed desk review of all complete proposals to assess their technical quality as well as the budget and time line suggested for the sub-project The environmental specialist member of the Project Coordinating Team (PCT) will review the proposal and prepare all needed documentation based on his classification of the sub-project

56 Screening of Sub-Projects

50 Each sub-project to be implemented by an IA will be subjected to an environmental screening Using the screening form (Form 1) environmental and social checklists for the proposed sub-projects will be screened by the environmental specialist to identify any potential adverse impacts

25

From an environmental standpoint the screening form may identify impacts form sub-projects the issue of solid waste disposal at the site of a sub-project may come out as a point to look at in terms of designing mitigation measures to avoid negative impacts The selection of adequate storage collection and proper disposal could be steps to consider carefully

57 The Environmental and Social Screening Process

51 The objectives of sub-project screening is to determine which activities are likely to have negative environmental and social impacts

571 Subproject Screening Procedures

52 The sub-projects funded under this project are generally categorized as Category B or C and screening mechanisms would ensure that any identified Category A sub-projects are not funded under the project Due to the fact that most Category B sub-projects are small-scale which do not result in adverse negative environmental impacts this will require an ESMP which has clear due diligence environmental and social procedures (including the setting out of institutional responsibilities timing and budget) for sub-projects The ESMP should take into consideration the applicable requirements under the Bankrsquos ten safeguard policies

572 Environmental Sub-Project Screening Checklistsforms

53 The Operation Manual (OM) should contain for each type of sub-project a simple environmental screening checklist (Form 1)) which poses a series of questions designed to identify risks to the environment The goal of the checklist (also called a screening or environmental data sheet) is to identify which sub-projects require more environmental information in the form of a site-specific ESMP or which can proceed without any special mitigation measures that is falling under category C

Form 1 Environmental Screening Check-list

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

22

Table 2 Training and Capacity Building Program for Implementing the ESAFTraining

Capacity BuildingParticipating Stakeholders

Skills acquired Scheduling Cost Source

ManagementInstitutional

1year

SPPP manager MOSA central unit Head of concerned

departments at MOSA PCT

Decision making and delegation Work procedures Environmental awareness National guidelines WB guidelines Classification and mitigation

Prior to sub-project preparation Planning phase Refresher every 3 months as we

go along the project

Undertaken by the Environmental

SpecialistMiscellaneous

7500 USD

WBMOSA

Institutional at Intermediate levels

2 training sessions of 2 days year

(for SDC and IA X5 regions)

PCT Emanating committee SDC managers IAs

Environmental and social policies

Laws and regulations GOL and WB safeguards Evaluation and selection

During sub-project preparation Planning phase Sub-project evaluation

Undertaken by the Environmental

SpecialistMiscellaneous

30000 USD

WB MOSA

Implementation1 day session X2 year X 5 regions

IAs SDC staff Beneficiaries Municipalities

Environment and social tools Screening amp monitoring

methods Sustainability of the process Practical mitigation and

safeguards

During sub-project preparation Mobilization Implementation

Undertaken by the Environmental

SpecialistMiscellaneous

50000 USD

WB MOSA

Monitoring Evaluation and

Reporting1 dayX2 year X5

regions

IAs SDC staff Beneficiaries

Municipalities

Environmental and social monitoring and compliance

Progress report preparation Monitoring and Evaluation

During sub-project preparation MobilizationImplementation

Environmental Specialist + consultant

50000 USD

WB MOSA

Total 137500 USD (includes in kind contribution from MOSA)

23

54 Environmental Monitoring

44 Environmental Monitoring will be the responsibility of the ES PCT and MOSA Central Unit with the supervision of the LCP and will include compliance monitoring during implementation and also monitoring of significant impacts during the operation of the subproject

Table 3 Typical Examples of Monitoring Plan for the Operation of Different Subprojects

Sub-project Monitoring Indicators Responsibility FrequencyRoads rehabilitation

Operating drainage channels

NGOs in close coordination with local community

Semi-annual assessment

Improvements to Water Supply and Sanitation Facilities

Irrigation and drainage

Distribution network without leaksNo leakage or overflows of manholes or drainsWater Quality Monitoring

Irrigation network without leaksDrainage channels clean and properly maintainedWater quality parameters (pH COD BOD SS)

NGOs in close coordination with local community

Ministry of Health and Ministry of Energy and Water

NGOs in close coordination with local community

Testing by Ministry of Health and Ministry of Energy and Water

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Rehabilitation of schools

Rehabilitation of health clinics

Toilet facilities clean and functioning properlyDrinking water faucets clean and safe from contamination

NGOs in close coordination with local community and appropriate municipality

Ministry of Health in close coordination with local community

Semi-annual assessment

Semi-annual assessment

23

24

45 The Environmental Specialist (ES) of the PCT will also conduct periodic monitoring by visiting the sites of the various sub-projects at least twice during the implementation period of the sub-project

46 Monitoring indicators shall be developed for both the mobilization and the operation phase of the subprojects Monitoring of activities will have to ensure that mitigation measures of operations impacts are being implemented properly while the monitoring of operation is to ensure that no unforeseen negative impacts are arising

55 Sub-project Cycle

47 Component 2 of the SPPP is the Community Social Development Program (CSD) which will be financing community-based sub-projects through grants The Program will have two windows one for social services whereas the other is for Income Generation Activities (IGA) support with the review and approval mechanisms in large part being the same for both windows While Component 3 focuses on Poverty Targeting thus the services provided will have no impact on the environment component 1 will focus on the provision of technology and training to SDCs

48 Applicants will be invited to use standard forms (available on the MOSA website and upon request from SDCs) to submit proposals to the relevant SDC in cases where the applicant is the SDC itself the application will be submitted directly to the CSD program team in Beirut

49 SDCs will immediately check all proposals for completeness and give a receipt to the applicant with a proposal number proposals found to be incomplete will be rejected with an explanation All complete proposals will be presented for discussion to the relevant Local Community Platform (LCP) or equivalent consultative body to obtain feedback on among other things the actual need (in case of social services) or likely market value (in the case of IGA) of the proposed activity the reputation of the applicant the likely sustainability of the proposed activity the preliminary classification of the project within environmental categories (the final classification will be pending on the decision of the environmental specialist within the PCT) any problematic aspect (conflict of interest etc) and the overall compliance of the proposal with the purposes of the program This feedback is not binding but will be taken into consideration when deciding whether or not to fund the proposal The CSD program team will carry out a detailed desk review of all complete proposals to assess their technical quality as well as the budget and time line suggested for the sub-project The environmental specialist member of the Project Coordinating Team (PCT) will review the proposal and prepare all needed documentation based on his classification of the sub-project

56 Screening of Sub-Projects

50 Each sub-project to be implemented by an IA will be subjected to an environmental screening Using the screening form (Form 1) environmental and social checklists for the proposed sub-projects will be screened by the environmental specialist to identify any potential adverse impacts

25

From an environmental standpoint the screening form may identify impacts form sub-projects the issue of solid waste disposal at the site of a sub-project may come out as a point to look at in terms of designing mitigation measures to avoid negative impacts The selection of adequate storage collection and proper disposal could be steps to consider carefully

57 The Environmental and Social Screening Process

51 The objectives of sub-project screening is to determine which activities are likely to have negative environmental and social impacts

571 Subproject Screening Procedures

52 The sub-projects funded under this project are generally categorized as Category B or C and screening mechanisms would ensure that any identified Category A sub-projects are not funded under the project Due to the fact that most Category B sub-projects are small-scale which do not result in adverse negative environmental impacts this will require an ESMP which has clear due diligence environmental and social procedures (including the setting out of institutional responsibilities timing and budget) for sub-projects The ESMP should take into consideration the applicable requirements under the Bankrsquos ten safeguard policies

572 Environmental Sub-Project Screening Checklistsforms

53 The Operation Manual (OM) should contain for each type of sub-project a simple environmental screening checklist (Form 1)) which poses a series of questions designed to identify risks to the environment The goal of the checklist (also called a screening or environmental data sheet) is to identify which sub-projects require more environmental information in the form of a site-specific ESMP or which can proceed without any special mitigation measures that is falling under category C

Form 1 Environmental Screening Check-list

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

23

54 Environmental Monitoring

44 Environmental Monitoring will be the responsibility of the ES PCT and MOSA Central Unit with the supervision of the LCP and will include compliance monitoring during implementation and also monitoring of significant impacts during the operation of the subproject

Table 3 Typical Examples of Monitoring Plan for the Operation of Different Subprojects

Sub-project Monitoring Indicators Responsibility FrequencyRoads rehabilitation

Operating drainage channels

NGOs in close coordination with local community

Semi-annual assessment

Improvements to Water Supply and Sanitation Facilities

Irrigation and drainage

Distribution network without leaksNo leakage or overflows of manholes or drainsWater Quality Monitoring

Irrigation network without leaksDrainage channels clean and properly maintainedWater quality parameters (pH COD BOD SS)

NGOs in close coordination with local community

Ministry of Health and Ministry of Energy and Water

NGOs in close coordination with local community

Testing by Ministry of Health and Ministry of Energy and Water

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Semi-annual assessment

Rehabilitation of schools

Rehabilitation of health clinics

Toilet facilities clean and functioning properlyDrinking water faucets clean and safe from contamination

NGOs in close coordination with local community and appropriate municipality

Ministry of Health in close coordination with local community

Semi-annual assessment

Semi-annual assessment

23

24

45 The Environmental Specialist (ES) of the PCT will also conduct periodic monitoring by visiting the sites of the various sub-projects at least twice during the implementation period of the sub-project

46 Monitoring indicators shall be developed for both the mobilization and the operation phase of the subprojects Monitoring of activities will have to ensure that mitigation measures of operations impacts are being implemented properly while the monitoring of operation is to ensure that no unforeseen negative impacts are arising

55 Sub-project Cycle

47 Component 2 of the SPPP is the Community Social Development Program (CSD) which will be financing community-based sub-projects through grants The Program will have two windows one for social services whereas the other is for Income Generation Activities (IGA) support with the review and approval mechanisms in large part being the same for both windows While Component 3 focuses on Poverty Targeting thus the services provided will have no impact on the environment component 1 will focus on the provision of technology and training to SDCs

48 Applicants will be invited to use standard forms (available on the MOSA website and upon request from SDCs) to submit proposals to the relevant SDC in cases where the applicant is the SDC itself the application will be submitted directly to the CSD program team in Beirut

49 SDCs will immediately check all proposals for completeness and give a receipt to the applicant with a proposal number proposals found to be incomplete will be rejected with an explanation All complete proposals will be presented for discussion to the relevant Local Community Platform (LCP) or equivalent consultative body to obtain feedback on among other things the actual need (in case of social services) or likely market value (in the case of IGA) of the proposed activity the reputation of the applicant the likely sustainability of the proposed activity the preliminary classification of the project within environmental categories (the final classification will be pending on the decision of the environmental specialist within the PCT) any problematic aspect (conflict of interest etc) and the overall compliance of the proposal with the purposes of the program This feedback is not binding but will be taken into consideration when deciding whether or not to fund the proposal The CSD program team will carry out a detailed desk review of all complete proposals to assess their technical quality as well as the budget and time line suggested for the sub-project The environmental specialist member of the Project Coordinating Team (PCT) will review the proposal and prepare all needed documentation based on his classification of the sub-project

56 Screening of Sub-Projects

50 Each sub-project to be implemented by an IA will be subjected to an environmental screening Using the screening form (Form 1) environmental and social checklists for the proposed sub-projects will be screened by the environmental specialist to identify any potential adverse impacts

25

From an environmental standpoint the screening form may identify impacts form sub-projects the issue of solid waste disposal at the site of a sub-project may come out as a point to look at in terms of designing mitigation measures to avoid negative impacts The selection of adequate storage collection and proper disposal could be steps to consider carefully

57 The Environmental and Social Screening Process

51 The objectives of sub-project screening is to determine which activities are likely to have negative environmental and social impacts

571 Subproject Screening Procedures

52 The sub-projects funded under this project are generally categorized as Category B or C and screening mechanisms would ensure that any identified Category A sub-projects are not funded under the project Due to the fact that most Category B sub-projects are small-scale which do not result in adverse negative environmental impacts this will require an ESMP which has clear due diligence environmental and social procedures (including the setting out of institutional responsibilities timing and budget) for sub-projects The ESMP should take into consideration the applicable requirements under the Bankrsquos ten safeguard policies

572 Environmental Sub-Project Screening Checklistsforms

53 The Operation Manual (OM) should contain for each type of sub-project a simple environmental screening checklist (Form 1)) which poses a series of questions designed to identify risks to the environment The goal of the checklist (also called a screening or environmental data sheet) is to identify which sub-projects require more environmental information in the form of a site-specific ESMP or which can proceed without any special mitigation measures that is falling under category C

Form 1 Environmental Screening Check-list

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

24

45 The Environmental Specialist (ES) of the PCT will also conduct periodic monitoring by visiting the sites of the various sub-projects at least twice during the implementation period of the sub-project

46 Monitoring indicators shall be developed for both the mobilization and the operation phase of the subprojects Monitoring of activities will have to ensure that mitigation measures of operations impacts are being implemented properly while the monitoring of operation is to ensure that no unforeseen negative impacts are arising

55 Sub-project Cycle

47 Component 2 of the SPPP is the Community Social Development Program (CSD) which will be financing community-based sub-projects through grants The Program will have two windows one for social services whereas the other is for Income Generation Activities (IGA) support with the review and approval mechanisms in large part being the same for both windows While Component 3 focuses on Poverty Targeting thus the services provided will have no impact on the environment component 1 will focus on the provision of technology and training to SDCs

48 Applicants will be invited to use standard forms (available on the MOSA website and upon request from SDCs) to submit proposals to the relevant SDC in cases where the applicant is the SDC itself the application will be submitted directly to the CSD program team in Beirut

49 SDCs will immediately check all proposals for completeness and give a receipt to the applicant with a proposal number proposals found to be incomplete will be rejected with an explanation All complete proposals will be presented for discussion to the relevant Local Community Platform (LCP) or equivalent consultative body to obtain feedback on among other things the actual need (in case of social services) or likely market value (in the case of IGA) of the proposed activity the reputation of the applicant the likely sustainability of the proposed activity the preliminary classification of the project within environmental categories (the final classification will be pending on the decision of the environmental specialist within the PCT) any problematic aspect (conflict of interest etc) and the overall compliance of the proposal with the purposes of the program This feedback is not binding but will be taken into consideration when deciding whether or not to fund the proposal The CSD program team will carry out a detailed desk review of all complete proposals to assess their technical quality as well as the budget and time line suggested for the sub-project The environmental specialist member of the Project Coordinating Team (PCT) will review the proposal and prepare all needed documentation based on his classification of the sub-project

56 Screening of Sub-Projects

50 Each sub-project to be implemented by an IA will be subjected to an environmental screening Using the screening form (Form 1) environmental and social checklists for the proposed sub-projects will be screened by the environmental specialist to identify any potential adverse impacts

25

From an environmental standpoint the screening form may identify impacts form sub-projects the issue of solid waste disposal at the site of a sub-project may come out as a point to look at in terms of designing mitigation measures to avoid negative impacts The selection of adequate storage collection and proper disposal could be steps to consider carefully

57 The Environmental and Social Screening Process

51 The objectives of sub-project screening is to determine which activities are likely to have negative environmental and social impacts

571 Subproject Screening Procedures

52 The sub-projects funded under this project are generally categorized as Category B or C and screening mechanisms would ensure that any identified Category A sub-projects are not funded under the project Due to the fact that most Category B sub-projects are small-scale which do not result in adverse negative environmental impacts this will require an ESMP which has clear due diligence environmental and social procedures (including the setting out of institutional responsibilities timing and budget) for sub-projects The ESMP should take into consideration the applicable requirements under the Bankrsquos ten safeguard policies

572 Environmental Sub-Project Screening Checklistsforms

53 The Operation Manual (OM) should contain for each type of sub-project a simple environmental screening checklist (Form 1)) which poses a series of questions designed to identify risks to the environment The goal of the checklist (also called a screening or environmental data sheet) is to identify which sub-projects require more environmental information in the form of a site-specific ESMP or which can proceed without any special mitigation measures that is falling under category C

Form 1 Environmental Screening Check-list

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

25

From an environmental standpoint the screening form may identify impacts form sub-projects the issue of solid waste disposal at the site of a sub-project may come out as a point to look at in terms of designing mitigation measures to avoid negative impacts The selection of adequate storage collection and proper disposal could be steps to consider carefully

57 The Environmental and Social Screening Process

51 The objectives of sub-project screening is to determine which activities are likely to have negative environmental and social impacts

571 Subproject Screening Procedures

52 The sub-projects funded under this project are generally categorized as Category B or C and screening mechanisms would ensure that any identified Category A sub-projects are not funded under the project Due to the fact that most Category B sub-projects are small-scale which do not result in adverse negative environmental impacts this will require an ESMP which has clear due diligence environmental and social procedures (including the setting out of institutional responsibilities timing and budget) for sub-projects The ESMP should take into consideration the applicable requirements under the Bankrsquos ten safeguard policies

572 Environmental Sub-Project Screening Checklistsforms

53 The Operation Manual (OM) should contain for each type of sub-project a simple environmental screening checklist (Form 1)) which poses a series of questions designed to identify risks to the environment The goal of the checklist (also called a screening or environmental data sheet) is to identify which sub-projects require more environmental information in the form of a site-specific ESMP or which can proceed without any special mitigation measures that is falling under category C

Form 1 Environmental Screening Check-list

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

26A Environmental and Social Impacts Yes No

Location

1 Are there environmentally sensitive areas (forests rivers or wetlands) or threatened species that could be adversely affected by the project

2 Does the project area (or components of the project) occur within or adjacent to any protected areas designated by government (national park national reserve world heritage site etc)

3 If the project is outside of but close to any protected area is it likely to adversely affect the ecology within the protected area areas (eg interference with the migration routes of mammals or birds)

4 Will the project reduce peoplersquos access (due to roads location etc) to the pasture water public services or other resources that they depend on

5 Might the project alter any historical archaeological or cultural heritage site or require excavation near such a site

Physical and biological environment

6 Will project require large volumes of construction materials (eg gravel stones water timber firewood)

7 Might the project lead to soil degradation or erosion in the area

8 Might the project affect soil salinity9 Will the project create solid or liquid waste that could adversely

affect local soils vegetation rivers streams or groundwater10 Might river or stream ecology be adversely affected due to the

installation of structures such as weirs and by-passes for micro-hydro projectsAttention should be paid to water quality and quantity the nature productivity and use of aquatic habitats and variations of these over time

11 Will the project have adverse impacts on natural habitats that will not have acceptable mitigation measures

12 Does the project have human health and safety risks during construction or later

13 Will the project lead to changes in the distribution of people or of livestock

14 Might the project lead to migration into the area

Alternatives

15 Is it possible to achieve the objectives above in a different way with fewer environmental and social impacts

A1

A2

A3

A4

Circle one of the following screening conclusionsAll answers to the checklist questions are ldquoNordquo There is no need for further action

For all issues indicated by ldquoYesrdquo answers adequate mitigation measures should be in the project design No further planning action is required Implementation of mitigation measures will require supervision by the applicant and the appropriate authorityFor the following issues indicated by ldquoYesrdquo answers (specify questions numbers) the applicant has not provided adequate mitigation measures

The applicant must revise the proposed project plan to provide adequate mitigation Specialist advice

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

27

NAME OF SUB-PROJECT

SIGNATURE

DATE

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

28

573 Assigning Environmental Categories

54 The assignment of the appropriate environmental category to a sub-project will be done after screening and will be based on the information contained in the environmental and social screening form The ES will be responsible for categorising a sub-project activity as B or C as elaborated below That is environmental screening will result in one of the following cases as per the World Bank OP 401 Environmental Assessment

1 Category A Any sub-project found to be category A will not be funded by this project

2 Category B An ESMP is prepared which includes the mitigation measures required as well as the means to monitor its implementation and any capacity building activities if necessary

3 Category C a project may be categorised as Class C if it is determined that it will have no significant or adverse impact on the environment Its activities do not necessitate any further environmental study ESMP or the like

As already mentioned all activities funded under the CSD are likely to be categorized as B or C for that matter This means that their potential adverse environmental impacts on human populations or environmentally important areas are reversible or neutral and mitigating measures are readily available for inclusion in the sub-project design

574 Carrying out Environmental Work

55 After analyzing the data contained in the environmental and social screening form and having identified the right environmental category and thus the scope of the environmental work required the ES will make a recommendation to the Project Coordinator establishing whether

i) No environmental work will be required orii) An environmental and social management plan (ESMP) is prepared the TORs of which

are provided in Annex III

575 Review and Approval

a) Review

56 At the central level the PCT with the assistance of the ES will review the environmental and social screening forms as well as the ESMP reports and will make recommendations as to whether the results of the screening process or the ESMP reports are acceptable That is to establish whether the following are appropriate

(i) the results and recommendations presented in the environmental and social screening forms

(ii) the proposed mitigation measures presented in the environmental and social checklists and

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

29

(iii) all environmental and social impacts have been identified and effective mitigation measures have been proposed and incorporated into the project implementation plan with associated costs

b) Recommendation for Approval

57 Once an ESMP is prepared the ES will review and ensure that it is carried out according to the TORs (a sample TORs is provided in Annex III) If found acceptable then the ESMP will be approved as per the next section

c) Approval

58 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and Environmental Specialist (ES) while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the ES will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

576 Environmental Monitoring and Follow-up

59 Environmental monitoring aims at checking the effectiveness and relevance of the implementation of the proposed mitigation measures The ES and LFP will depending on the scale or scope of the sub-projects undertake the monitoring exercises in sequences and frequencies stipulated in the Environment Management Plan (including where appropriate a Maintenance Schedule)

577 Monitoring indicators

60 The monitoring indicators will be developed based on the mitigation measures and the Environmental Management and Social Plan (ESMP)

58 Staffing and Capacities of MOSA in the management of Environmental safeguards

61 The Ministry of Social Affairs does not dispose of any environmental specialists within its structure MOSA had contracted at needed instances the services of environmental consultants on ad-hoc basis and on short term assignments upon the request of donor agencies to monitor the implementation of some social development projects This had not instituted in any way the presence of expert in this domain For this and in order to ensure the proper adherence to the safeguards set by the project the PCT will contract the services of an Environmental Specialist (ES) on part time basis

62 The ES will consolidate all the needed documentation for the proper classification selection evaluation and monitoring of the project He She will conduct session to sensitize decision makers at MOSA on the importance of looking at the safeguards as well as explain in details the requirements set by the MOE and the World Bank in that regard The ES will design the training material needed at the different levels and in the different stages of the project He

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

30

She will have to interact with key players in the field in addition to CSOs interested in submitting sub-projects for financing The ES will coordinate with concerned municipalities on sub-projects implemented within their area of operation

63 The ES will be able to use the services of expert on need basis based on clear Terms of reference set by the ES approved by the PCT manager and MOSA and cleared by the WB The EC will also liaise with Environmental NGOs to look into possible coordination with other eligible IAs at the level of implementation of Sub-projects

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

31

Flowchart on the approval mechanism for CSD sub-projects

Responsibility Review and approval mechanism for CSD sub-projects

Submit proposal

Provide non-binding feedback on sub-project appropriateness

Technical desk review(2 teams depending on windows)

Verify documentation complete (can be done by admin staff)

Complete give receipt amp move

Not complete =gt give checklist

Revise amp re-submit and send note

Field assessment

Reject amp send note

Income generating activitiesSocial services

CSD Program manager

Validation

pass

Evaluation amp scoring (AcceptRejector send back for revisions then submit

directly for desk review)

SDC level

CSD Program teamSocial teamIGA team

Field assessment

Evaluation amp scoring (AcceptReject or send back for revisions then submit

directly for desk review)

Approval

Notify applicantsamp publish on MOSA website and SDCs bulletin

board

Emanating committee

Contract signature by winner

Applicants

LCPs

CSD Program team

Minister

Winner

Contract counter-signature by the Minister or DGMinisterDG

Recommend acceptance or rejection Recommend acceptance or rejection

Environmental Screening Form

Environmental Review ESAF

EIA ESMP

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

32

6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES

61 Status of the SPPP Environmental Review

64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation

62 Institutional Arrangement

65 During project implementation the PCT will be responsible for the project administrationFor Category B programs andor sub-projects the PCT will contract the services of an Environmental Specialist who will be responsible for

o Reviewing the environmental screening of the program submitted by the IAso Reviewing and approving the ESMP if sub-project is deemed category BO Obtaining the approval of the Ministry of Environment (MOE) for the sub-

projects requiring an ESMP after year 2 O Conducting periodic monitoring of the programso Preparing annual report of the environmental situation of the SPPP

63 MOSA through the ES will be in charge of the environmental operation of the program Implementing bodies in the community will be selected in accordance with specific criteria of which that they will have or could contract or consult for the services of an environmental specialist familiar with community development projects to perform the following duties

a) Promote the environmental requirements and guidelines of the SPPP among NGOs and communities

b) Ensure that the environmental screening form is properly filled c) Provide assistance to NGOs in preparing the environmental assessmentd) Conduct site specific environmental review in order to review the current environmental

conditions of site and assess the potential environmental impact associated with the proposed subproject

e) Identify mitigation measures in operationf) Supervise the implementation of environmental management plansg) Prepare necessary reportsh) Validate the effectiveness of the ESMP prepared

64 IAs will be encouraged to use the capacities of specialized environmental NGOs to provide technical assistance and help These NGOs could also be used by the project for the provision of training and capacity building when needed

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

33

63 Program Cycle

65 In the PAD and Operational Manual of the Project it will be MOSArsquos responsibility to conduct appropriate screening of the individual sub-projects in accordance with the environmental screening checklist

66 SPPP funded subprojectsprograms will follow a well-defined project cycle that is detailed in the Project Operational Manual The manual defines the steps required to implement the subprojects and includes the procedural forms reviews and measures to ensure proper execution

67 Environmental review procedures will be incorporated in the project cycle at the program and sub-project level The time frame for the completion of the environmental procedures will be the same as those given in the Operational Manual for the completion of the administrative and technical procedures Table 4 summarizes the environmental procedures within each stage of the SPPP Programsubproject cycle

Table4 Environmental Requirements within Each Stage of the CSD ProgramSubproject Cycle

Sub-project Development Environmental RequirementsSub-project identification

- Identification of demand driven subprojects- Preparation of subprojects concepts

- Screening of subprojects by SDC LCP- Preparation of Environmental Checklist by Implementing Agency- Approval of EDS by PCT

Sub-project Preparation

- Description and analysis of subprojects

- Subproject approvals

- Preparation by IA or consultants of (i) EA report in case subprojects have significant impacts or(ii) ESMP on the basis of generic mitigation plans

- Inclusion of mitigation measures in subproject design

- Approval of the ESMP by the Environmental Specialist and no objection of WB for the first two (2) years and then the approval of the MoE and random spot checks from World Bank for the remaining three (3) years of the project

Program financing - Ensure that environmental requirements are included in subproject agreement with NGOs

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

34

Program Monitoring and supervision

- At the subproject levelImplementation of subprojects

- At the program levelSupervision of contractsworks

- At the subproject level(i) PCT to ensure that mitigation measures and monitoring measures are implementedLCP could assist in monitoring(ii) PCT to prepare annual report on status of EMPs

- At the program level Preparation by the PCT of annual report summarizing

The number of subprojects that have significant environmental impact

The number of projects for which EMPs were prepared

The mitigation measures implemented for subprojects that have significant environmental impacts

Training and workshops presented

64 Promotion of Subprojects

68 The first stage in the SPPP subprojects cycle is to initiate promotional activities and prepare demand driven subprojects MOSA primary responsibility would be to initiate promotional programs that aim at disseminating information about the SPPPrsquos objectives guidelines and procedures among targeted community groups Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle SDCs would have to educate communities and to raise awareness on environmental issues and requirements of SPPP subprojects This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects

65 Formulation of Sub-projects

69 Following the implementation of promotional programs community needs and priorities will be identified project proposals will be formulated and a program will be submitted to the PCT for appraisal

70 With respect to environment the first step would be to screen each sub-project and identify whether any further environmental considerations are required The purpose of this is to identify early in the sub-project cycle the need to address potential environmental impacts during the project preparation and design On the other hand an effective screening will identify sub-

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

35

projects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review (that is Category C) Once all the subprojects of a program have been screened an environmental data sheet (EDS) for the program should be prepared

71 Sub-projects that necessitate environmental consideration will either require the identification and implementation of mitigation measures or the preparation of an ESMP For these sub-projects the ES of the PCT will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents

66 Approval of Program

72 If the desk review and the preliminary environmental classification completed by the LCP and the SDC have an overall positive outcome for a sub-project falling within Categories B and C a field assessment will be conducted The Environmental Specialist within the PCT will make sure that sub-projects requiring ESMPrsquos ldquoBrdquo Category according to the World Bank guidelines and as per the generic TORs in Annex II will be completed

73 The World Bank will review and clear all ESMPs during the first two years of project implementation Thereafter the Bank will rely on the review of the PCT and environmental specialist while maintaining the right to conduct a spot check on random ESMPs during the remaining three years of project implementation In any case the Environmental Specialist will ensure that all the needed approvals on the ESMPs are obtained from the MOE as deemed relevant and necessary

67 Implementation and Monitoring

74 Upon approval of the sub-project proposal arrangements regarding implementation and monitoring will be contained in the legal contract signed between the IAs and MOSA It would be necessary that the PCT ensures that the results of the environmental assessment (special mitigation measures design specifications supervision plans and monitoring arrangements) are incorporated into the legal document Environmental monitoring of a project performance will start with the mobilization phase and will extend to the operation phase

75 The execution of the subproject contract and construction supervision is the responsibility of the IAs Where they do not have adequate in-house resources the IAs will be responsible for the appointment of a supervision consultant Part of the construction supervision duties is to ensure that mitigation measures are properly implemented good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

36

ANNEX I

Primary objectives of mitigation measures

Mitigation measures aimed at eliminating offsetting or reducing adverse environmental impacts can have a range of objectives Some of these are briefly defined below in approximate order of priority The first priorities are avoidance or prevention of impacts whereas the priority of the other categories is less rigid

Avoidance Avoiding projects or activities that could result in adverse impacts avoiding certain types of resources or areas considered to be environmentally sensitive This approach is most effective when applied in the earliest stages of project planning

Prevention Measures aimed at impeding the occurrence of negative environmental impacts andor preventing such an occurrence having harmful environmental and social impacts

Preservation Preventing any future actions that might adversely affect an environmental resource or attribute This is typically achieved by extending legal protection to selected resources beyond the immediate needs of the project

Minimization Limiting or reducing the degree extent magnitude or duration of adverse impacts Mitigation can be achieved by scaling down relocating or redesigning elements of a project

Rehabilitation Repairing or enhancing affected resources such as natural habitats or water sources particularly when previous development has resulted in significant resource degradation

Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state typically ldquobackgroundpristinerdquo condition

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

37

ANNEX IIEnvironmental framework in Lebanon

Lebanon Country Environmental Analysis reported by the World Bank on June 20118 revealed that the environmental neglect had an impact on the economy and resulted in a degradation amounting to US$ 565 million in 2000 or 34 of GDP for local environment and US$ 655 million or 39 when global environment is included Environment has remained a secondary priority characterized by an uncompleted legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms These challenges are

1048696Regional disparities in poverty levels are significant with most poor areas being rural and with poverty pockets found within and around cities Poverty in these regions is related to the lack of public infrastructure and services lack of employment opportunities population density school dropout and child labor particularly in the northern region of Lebanon (ie Hermel and Akkar)

1048696There are still continued pressures on Lebanonrsquos natural resources especially water of which 64 is for agriculture and 26 is for domestic demand with 1-2 days a week limited access of potable water due to poor services

1048696Wastewater connections covered 66 of households in 2007 but wastewater treatment is lagging behind The wastewater network is only in major urban areas and there are only 11 wastewater treatment plants Of the 348 million of m3 of raw waste water in 2010 only 134 percent is treated with 73 percent of the BOD5 removed and the remaining wastewater is discharged into valleys rivers and the Mediterranean SEA

1048696Municipal solid waste collection seems to have been resolve whereas disposal remains a persistent issue Lebanon generates a total of 14 million tonsyear of which53 (750000 tonsyear) is disposed in two sanitary landfills (Nahmeh and Zahle) and the remaining is disposed in a contained landfill (Tripoli) and 700 open dumps

1048696High urban pressure on the Lebanese coast line is witnessed in most of its 225 km It is manifested by progressive and tacit privatization of public domains change of structures (such as polders) private marinas accelerated erosion and loss of agricultural land Incidentally Lebanonrsquos per capita land availability is among one of the lowest in the world at 00024 km2capita

1048696Lebanonrsquos natural heritage is being impacted by uncontrolled urban sprawl quarries and solid waste dumps resulting in a progressive pressure on major outstanding natural sites such as the Karst heritage of Lebanon in the Caza of Kesrouan and the natural bridge of Fakra and Nabaa el Laban

8Report No 62266-LBRepublic of Lebanon- Country Environmental AnalysisSustainable Development Department (MNSSD)Middle East and North Africa Region- June 2011

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

38

1048696The Governance system is based on a special interest group approach Governance in terms of access to environmental information communitystakeholders participation in the design and implementation of environmental services efficiency and transparency of public expenditures of environment-related expenditures is weak The political economy predominates when it comes to the ownership or management of natural assets and resources (water coastal areas and land)

Despite considerable progress in shaping its legal and institutional framework and providing substantial public funds for financing its infrastructure after the war Lebanon is still at an early stage of its transition to environmental sustainability Lebanonrsquos economic growth is not accompanied with an improvement in environmental sustainability which remains low

The GOL has started delivering on sectoral reform since 2009 in line with the GOL key objectives The Ministry of Energy and Water (MOEW) has submitted a plan to reform the electricity sector (US$ 49 billion over 4 years) and has prepared the National Water Sector Strategy (US$ 51 billion over 5 years) that covers the water wastewater and irrigation sectors that approved by the Council of Ministers in March 2012 Parliament has adopted the Oil and Gas Bill notably comprising the setting up of a sovereign fund to manage the proceeds of future revenues from offshore oil and gas production the Ministry of Post and Telecommunications is engaged in a comprehensive reform of the sector the Ministry of Environment (MOE) together with the Council for Development and Reconstruction (CDR) has prepared an updated solid waste management (SWM) Plan that was submitted to the Council of Ministers for approval and the Ministry of Social Affairs has started the implementation of the National Poverty Targeting Program funded by the Government of Lebanon World Bank Canadian International Development Agency Italian Government

Although acknowledged by the GOL the environment has nevertheless remained a secondary priority characterized by an incomplete legal and institutional framework as well as by ineffective policies to address the challenges and political constraints to deliver reforms The pre-Civil War cumulative neglect and the post-Civil War economic recovery called for badly needed environmental safeguarding and management by the GOL Hence the Ministry of Environment (MOE) was established in 1993 to address environmental challengesThe Framework Law 4442002 for the Protection of the Environment was promulgated to ensure the environmental sustainability The Law was supplemented by the decree 86332012 on Environmental Impact Assessment (EA) and followed by a Taameem for the Presidency of Council of Ministers n 282012 Law 6902005 reorganized the MOE but 4 years were necessary to issue Decree 22752009 that regulated and defined the units their functions and responsibilities Most protection measures in line with international conventions ratified by the GOL were enacted such as preparing a Strategy on Biodiversity producing the first and second communication to the UNFCCC (1999 and 2011) implementing a five-year plan for reforestation setting up the Lebanese Environment and Development Observatory (LEDO) that was unfortunately dismantled at the end of the project establishing national standards through LIBNOR and issuance of a Decree 82132012 on Strategic Environmental Assessment (SEA) Conversely the badly needed ratification by Parliament of the Integrated Coastal Zone Management Protocol (2008) of the Barcelona Convention to help curb the rapid artificialization of the coast due to the construction boom is initiated

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

39

On the policy side the MOE prepared its State of the Environment Report (SOER) and a Strategy Framework in 1996 This was followed by the preparation of the Second SOER in 2002 (and which is currently being updated forthcoming in June 2011) as well as the draft European Commission (EC) National Environmental Action Plan (NEAP) in 2006 that was updated into StREG and in which the MOE articulated its environmental strategy with seven objectives The GOL introduced an effective policy in 2002 to ban lead in gasoline and prohibit the use of diesel engines for taxis by providing an incentive system for converting light diesel engines into gasoline ones Most recently in January 2010 the MOE has prepared a very ambitious program of the themes to be implemented in cooperation and partnership with relevant stakeholders A decree created the National Council for Environment (NCE) and worked closely on the development of the Rio+20 report of Lebanon With all these strides at designing policies and formulating strategies namely the MOE Plan of Work 2011-2013 and the Strategy the environment domain has moved from the narrow interest of a limited number of professionals to become one of the national challenges for the Lebanese society

The World Bank has developed a partnership with the GOL through the preparation of a Country Environmental Analysis (CEA) which is aimed at providing the analytical underpinning for integrating environment into the development process The Lebanon CEA has the following three main objectives

Provide a comprehensive overview of Lebanonrsquos performance with regard to environment sustainability during the last ten to fifteen years

Facilitate mainstreaming of specific environmental issues into relevant sector activities for strengthening the development process and poverty alleviation efforts and

Guide and assist in the capacity building and strengthening process as pertains to specific environmental priorities as well as in relation to mainstreaming of global environmental issues with those at the national level Environmental sustainability performance with emphasis on Environment-Related Spending (ERS) as a proxy for the Public Expenditure Review for the Environment (PERE) to determine the effectiveness efficiency and equity of the supply of fiscal funds and including a rapid update of the national COED

Solid Waste Management (SWM) including cost of mitigation options to determine the demand for funds

Waste Water Management (WWM) including cost of mitigation options to determine the demand for funds and

Policy and institutional assessment including the EAFor the four above issues Lebanon faces the following challenges

Pollution scale is high and high also is the cost of addressing it This would necessitate the prioritization of the two target sectors at the urban and possibly at the governorate levels and the provision of these sector services

The infrastructure system and investment portfolio were built according to an engineering approach in which politics and low accountability were prevailing This led to poor service delivery for disposal and treatment resulting in the unwillingness from the users to pay for these services and therefore depriving the operators with additional resources to maintain the system

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

40

Utilities and operators at the sub-national entities such as municipalities and regional agencies are not creditworthy and cannot raise private capital Given such constraints municipalities and utilities prefer to finance the collection of wastewater and solid waste which would bear health benefits for the dwellers However they have little financial incentives to treat these wastes as these are considered as a public good hence requiring large state budget interventions

Municipal solid waste and drainage network (Arsifa wa Majarir) fee levels are very inadequate for effective cost recovery and their effects on revenues for sustainable operations and maintenance (OampM) are negligible Low fees and low cost recovery were not however financial barriers for private sector involvement as contractual agreements were reached but were subsidized by the GOL municipalities or utilities Nevertheless policy reforms in terms of increasing low feestariffs achieving cost recovery and clearing cross-subsidization (eg Electriciteacute du Liban etc) have lagged behind for political and social reasons adversely affecting the public debt in general and the sustainability of new investments in particular

The GOL is still using centrally-directed supply-driven approaches to provision of sanitation and municipal waste service infrastructure with limited communication and inputs form the immediate usersbeneficiaries and stakeholders of these services at the local level

Treatment standards required for municipal wastewater treatment and municipal solid waste (MSW) disposal facilities are high which would increase investments costs

Water pollution is expected to increase due to increased urbanization expansion of industrial activities and increased tourist infrastructure Moreover the climate change effects on water resources are projected to be significant over the next decades which would increase the water scarcity and alter the water balance

The results of the four environmental indicators showed that Lebanon economic growth is not accompanied with an improvement in environmental sustainability which remains low In order to protect the welfare and the quality of life of present and future generations Lebanon needs to build its economy around and not against its natural resources Lebanon development strategies should place environmental sustainability needs at similar levels of priority as its economic growth There is still a strong emphasis on investments as are mediation for environmental problems with less impressive progress on policy reforms Such levels of financing can no longer be sustained with the increase of the GOL debt and the decline in GOL revenues which cannot be used to finance additional basic environmental services such as water supply sanitation and waste management in rural areas or in social sectors Under such circumstances Lebanon has no alternative but to proceed with public expenditure efficiency based on output performance impose gradually the recovery of services and resource utilization costs and internalize the environmental degradation costs

In understanding and trying to improve the environmental policies and institutions in Lebanon it will be useful to take into consideration the following realities

a) Political economy As in all sectors environment is not immune to the political dynamics prevailing in Lebanon though it was supposed to be less vulnerable and politically neutral There is a general consensus among all parties and confessions that environmental protection and

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

41

preservation in Lebanon is crucial to its economic growth However when it comes to the ownership or management of natural assets and resources (water coastal areas and land) special interest groups prevail and preempt or delay the equitable use of these public goods

b) Decision-making process limited to the COM There is no effective mechanism other than the COM for coordinating the policy formulation processes In all cases environmental policy decisions are made at the highest levels of the government The COM is the only political body capable to reach consensual decisions Trade-offs forms the crux of decision-making and typically environmental considerations carry less weight than social economic and political factors When making decisions those responsible rely upon the advice of their officials and advisors whose views are likely to be shaped by their political mandates and responsibilities The general receptivity of decision-making will also depend upon the perceived acceptance by other parties In this regard perseverance is needed to build up consensus on environment-related decisions over time as this was witnessed in the case of the issuance of the Law establishing the MOE The Parliamentary Committee for Environment which was established in 2000 includes 12 parliamentarians as its permanent members Although its role is advisory in nature the Committee has held several debates on water wastewater and solid waste

c) Private sector-led approach to environmental services There can be little doubt that the Lebanese private sector has played a major role in providing environmental services during the last 15 years Project design management and supervision of national projects financed by the State budget and Development Partners through the CDR are all outsourced to the private sector The MOE as stated above is outsourcing its project management of grants to individual consultants private universities and consulting firms There is clear evidence that the private sector does possess the characteristics for continuing to provide effective environmental services however the lack of transparency and sometimes competition constitute a barrier to providing these services at efficient or reasonable costs

Lebanon has achieved improvements in its environmental legal framework mainly through the enactment of the Framework law for the Protection of Environment 444 (2002) the health care waste management decree the enacted EA decree developed with the assistance of the World BankMediterranean Environmental Technical Assistance Program(METAP) and several environmental standards developed under Strengthening The Permitting ampAuditing System for Industries (SPASI)60 Based on a command and control approach law 444has included in its article 4 the principles of the Rio Declaration on Environment and Development (1992) on public participation (principle 10) enacting effective environmental standards (principle 11) compensation for pollution and environmental damage (principle 13) precautionary principle (principle 15) internalization of environmental costs (principle 16) and environmental impact assessment (principle 17) In addition Law 6902005 and the decree 22752009 enabled the reorganization of the MOE functions and the introduction of the provisions to create an environment police that would allow enforcing environmental law and penalizing contraveners Law No 4442002 calls for 25 decrees to be implemented including the Environment Impact Assessment decree Lebanon has also signed more international agreements on environmental issues than in any other countries in the MNA countries and ranked second in signing regional conventions reflecting Lebanon keen interest in joining the world community

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

42

on environmental matters Lebanon is also the first MNA country to have prepared a draft decree on strategic environmental assessment which is still under examination

Government EA studies are being undertaken for most projects especially those that are being funded by International Organizations and Lending Agencies The EMSU unit at MOE has started reviewing EA reports submitted by many operators EA are being conducted based on the procedures set in the Compliance decree and developed in the EA decree which comply with the World Bank EA requirements

During the past few years environmental units have been created as part of the project implementation arrangements of several projects Other ministries have developed environmental guidelines to provide guidance in the preparation and implementation of environmentally sound projects METAP has also financed a series of EA training workshops for line ministries as well as EA awareness workshops for municipalities

ANNEX III

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

43

Terms of Terms of Reference for the preparation of anEnvironmental Management amp Social Plan (ESMP)

for the sub-project ldquoNAMErdquo funded by the Lebanon Social Promotion and Protection Project (SPPP)

1 Background

The government of Lebanon has obtained a US$ 30million loan from the World Bank for the purpose of implementing the Social Promotion and Protection Project (SPPP) which lays the lsquogroundworkrsquo to increase access to social development services at the community level improve the coverage and targeting of the National Poverty Targeting Program (NPTP) and build the capacity of the Ministry of Social Affairs (MOSA) at the central and the Social Development Center (SDC) levels

The duration of the SPPP project is 5 years and the project will be implemented throughout Lebanon The SPPP consists of 3 components

Component 1 Social Development Centers

Component 2 Community Social Development Program

Component 3 National Poverty Targeting Program

An important percentage of the funding will be allocated Funding community-driven sub-projects under component 2

Given the nature of these activities and as per World Bank environmental and social policies the borrower will need to prepare an Environmental Management and Social Plans (ESMPs)

The implementing agency responsible for this project is the Ministry of Social Affairs (MOSA) which will also be responsible for the implementation of the SPPP ESAF as well the environmental management and social plans(ESMPs) for the sub-projects object of these Terms of Reference

2 Project Description

The SPPP under component 2 will provide grants to eligible applicants (primarily SDCs and CSO) whose sub-projects have been selected through the national funding mechanism and will consist of two windows as follows

(i) Social services The SDCs as well as NGOs and local authorities will be invited to apply for grants in support of social services that address a proven social need within the community and which are in line with the mandates of the SDC (eg targeting children elderly youth at risk school dropouts disabled drug addicts and their families victims of domestic violence) To ensure a level-playing field and avoid conflicts of interest separate calls for proposals will be issued to SDCs or to other entities Eligibility and selection criteria will be specified in the Operations Manual

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

44

(ii) Income generating activities Grants will be made available to associations cooperatives and NGOs to support income generating activities benefitting vulnerable members in the community (eg female heads of households members of NPTP households the disabled youth and the long-term unemployed) Eligibility and selection criteria will be specified in the Operations Manual and will include technical feasibility sustainability environmental impact potential for employment creation and benefits to the community as a whole

3 InstitutionalImplementation Arrangements

Ministry of Social Affairs (MOSA)is responsible for the implementation and supervision of the ESMP object of these TORs Within MOSA the SPPP will finance a team (Project Coordinating Team PCT) who will be responsible for (i) overall project coordination working closely with the teams responsible for the implementation of the other project components reporting to the Minister on overall project progress (ii) implementation of the fiduciary functions of the project including procurement financial management and internal audit as well as that ensuring external audits undertaken in compliance with requirements and (iii) supporting the management of Component 1 (iv) observe the environmental safeguards during sub-projects implementation The PCT is foreseen as a temporary structure set up only for the duration of the project For this reason it is expected that during project implementation the PCT will actively contribute to build the capacity of the various actors involved in the implementation of the other three components particularly concerning core functions such as MampE procurement and financial management In addition the PCT will use the services of an Environmental Specialist (ES) to overlook the compliance with the respective ESAF of sub-projects

4 Safeguards Considerations

On the basis of the activities financed by this sub-project and on the expected environmental and social impacts the following World Bank Policies are applicable

- Operational Policy 401 on Environmental Assessment

Furthermore the project should abide by the Lebanese Law 222 for 2002 pertaining to environmental protection According to the law and also to the EIA application decree 8633 2012 any new project or any changes to an existing project should prepare an environmental impact assessment (EIA) report and submit it for review and approval by the Ministry of Environment (MOE) Construction should not commence prior to the approval of the EIA by MOE

According to the World Bankrsquos OP401 this sub-project is classified as Category B requiring partial assessment at the level of an environmental and social management plan (ESMP) According to the Lebanese EIA guidelines projects classified as Category B require the preparation of a ldquoForm Brdquo The requirement of the Bank and MOE are therefore fairly similar

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

45

5 Scope of Work

The consultant selected for this assignment will have to conduct the preparation of the Environmental and Social Management Plan (ESMP) of the sub-project that will include the following aspects

Mitigation

The ESMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels The plan includes compensatory measures if mitigation measures are not feasible cost-effective or sufficient Specifically the ESMP

(a) identifies and summarizes all anticipated significant adverse environmental impacts(b) describesmdashwith technical detailsmdasheach mitigation measure including the type of impact to which it relates and the conditions under which it is required (eg continuously or in the event of contingencies) together with designs equipment descriptions and operating procedures as appropriate and(c) estimates any potential environmental impacts of these measures

Monitoring

Environmental monitoring during project implementation provides information about key environmental aspects of the project particularly the environmental impacts of the project and the effectiveness of mitigation measures Such information enables the MOE and the Bank to evaluate the success of mitigation as part of project supervision and allows corrective action to be taken when needed Therefore the ESMP identifies monitoring objectives and specifies the type of monitoring with linkages to the mitigation measures described in the ESMP Specifically the monitoring section of the ESMP provides

(a) a specific description and technical details of monitoring measures including the parameters to be measured methods to be used sampling locations frequency of measurements detection limits (where appropriate) and definition of thresholds that will signal the need for corrective actions and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures and (ii) furnish information on the progress and results of mitigation

Capacity Development and Training

To support timely and effective implementation of environmental project components and mitigation measures the ESMP draws on the assessment of the existence role and capability of the SPPP PCT or MOSA If necessary the ESMP recommends the establishment or the expansion of such units and the training of staff to allow implementation of ESMP recommendations Specifically the ESMP provides a specific description of institutional arrangementsmdashwho is responsible for carrying out the mitigation and monitoring measures (eg for operation supervision enforcement monitoring of implementation remedial action financing reporting and staff training) To strengthen environmental management capability in

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

46

the agencies responsible for implementation the ESMP should cover one or more of the following additional topics (a) technical assistance programs (b) procurement of equipment and supplies and (c) organizational changes

Implementation Schedule and Cost Estimates

For all three aspects (mitigation monitoring and capacity development) the ESMP provides (a) an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans and (b) the capital and recurrent cost estimates and sources of funds for implementing the ESMP These figures are also integrated into the total project cost tables

Integration of ESMP with Project

The borrowers decision to proceed with a sub-project and the Banks decision to support it are predicated in part on the expectation that the ESMP will be executed effectively Consequently the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities and it must be integrated into the projects overall planning design budget and implementation Such integration is achieved by establishing the ESMP within the sub-project so that the plan will receive funding and supervision along with the other components

6 Reports

The Consultant will prepare a single report for this assignment on the basis of the following indicative outline

introduction description of project expected impacts from the project mitigation plan (see Table 1) monitoring plan (see Table 2) capacity strengthening plan (see Table 3)

7 Planning

This assignment will be carried out within a timeframe of 1 month and half from the time of the service order

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

Table 1

SUBPROJECT NAME

Environmental amp Social Management Plan TemplatesA Mitigation Measures

Sub-projectActivity

PotentialEnvironmental amp Social Impacts

Proposed Mitigation Measure(s)(Incl legislation ampregulations)

Institutional Responsibilities (Incl enforcement ampcoordination)

Cost Estimates

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Table 2

Ministry of Social Affairs- RN Page 47

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

SUBPROJECT NAMEEnvironmental amp Social Management Plan Template

Training amp Capacity Building for Implementation

TrainingCapacity Building

Participating Stakeholders

Skills acquired Scheduling Cost Source

Ministry of Social Affairs- RN Page 48

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

Table 3SUBPROJECT NAME

Environmental amp Social Management Plan TemplateMonitoring

Proposed Mitigation Measure

Parameters to beMonitored

Location Measurements (Incl methods ampequipment)

Frequencyof Measurement

Responsibilities(Incl review and reporting)

Cost(equipment ampindividuals)

Pre-Construction Phase

Construction Phase

Operation and Maintenance Phase

Total Cost for all Phases

Page 49

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

ANNEX IVPublic Consultation

Within the preparation stage of this document the consultation was done in 2 stages

1- Technical scoping session was held on Tuesday November 27 2012 to discuss the technical scope of this ESAF The participants in this consultation were

Name of Participant Organization1 Mr Ghassan Sayyah Ministry of Environment2 Dr Manal Mousallem Ministry of Environment3 Dr Lamia Mansour Environmental Fund for Lebanon4 Ms Sawsan Abou

FakhredineAssociation for Forest Development and Conservation

5 Mr Ziad Abdul Samad Arab NGO Network for Development6 Mr Karim El Jisr Lebanon Mountain Trail

The participants looked holistically at the document and touched on some direct technical issues The points that were considered looked at

The need to integrate carefully the economic political and environmental dimensions in very analysis and evaluation of a sub-project This would require a more systemic approach rather than technical

CSOs should be looked as partners rather than implementing agencies The contribution of the private sector is very valuable and it needs to be brought in as a

partner However before doing that we need to establish a legal framework that pushes the private sector to do more for the environment through linking it to economic growth and better performance of the sector In that respect we need to ensure that the private sector abides by rules and regulations that link its expansion to national and local economically environmentally sustainable projects

There exists the need to build the capacities of CSO in this field This capacity building could be embedded within new initiatives that could be linked to the quality of the sub-projects

All the above could be incorporated as part of a series of workshops that would help look comprehensively at the process

The decree 86332012 on EA could replace the WB guidelines since these are very similar

Need to generate a catalogue of projects and need to look at the Strategic Environmental Assessment (SEA) before finalizing any design Some of the suggested areas of work include Youth and education Energy (small innovative technologies) Information technology and ecosystems services Page 50

2 Public Consultation workshop was held on January 25 2013 (invitation letter is provided in Annex V) This consultation workshop was attended by

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

Name of Participant Organization1 Mr Rabih Abdel Khalek Lebanese House for Environment

Association2 Mr Kamal Nakhle Lebanese Forum for the Preservation of the

Environment3 Mr George Azar Rotary Clubs in Lebanon4 Ms Wafa Khoury Lions club ndash Lebanon5 Mr Jean Khoury Lions club ndash North Lebanon6 Dr Ahmad Dirani Lebanese Observatory for the rights of

workers7 Mr Rami Chama Association for the Development of the

Individual and the Environment8 Mr Jawad Abou Ghanem Association for Forest Development and

Conservation9 Mr Fadi Halabi EDAN10 Dr Fahmia Charafeddine Civil Committee for Women Welfare11 Mr Samir Skaff Green Globe12 Mr Samia Diab Association for Women Causes13 Dr Fifi Kalab Byblos Ecologia

Green Square14 Ms Patricia Sfeir Zero Waste Coalition

Beyond Association15 Mr Paul Abi Rached TERRE Liban16 Ms Lara Haidar Ministry of Environment17 Mr Tony Sadeh Friends of Ehden Reserve18 Dr Suhair Ghali Obeid Ministry of Social Affairs19 Mrs Fernande Abou Haidar Ministry of Social Affairs20 Mrs Abir Abdul Samad Ministry of Social Affairs21 Mrs Salam Shreim Ministry of Social Affairs22 Mr Ramzi Naaman Presidency of Council of Ministers MOSA23 Mr Alaa Sarhan World Bank

attended the meeting as an observer

The project was described and the ESAF was put in the context of the project with a clear emphasis on the need to look at the Social and Environmental dimensions The categories of projects that will be considered for financing were explained and how the environmental planning needs to be embedded within the project documents since the start

The participants stressed on the (i) participatory approach that needs to be strengthened throughout the process of sub-project preparation and the need to involve the local community in the sub-project design and the sub-project environmental and social screening (ii) need to coordinate between the different stakeholders concerned in the implementation of the sub-projects They highlighted the importance of bringing together the different expertise of the NGO sector in the mode of assessment and implementation (iii) need to simplify the forms and the

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

procedures to be undertaken to allow for a fair and equal participation among all interested (iv) capacity building remains a cross-cutting request to strengthen the technical know-how of NGOs in environmental planning and impact assessment Names amp Contact Information of Consultation Participants

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an

ANNEX V

The Invitation to the consultation

البنك مع بالتعاون االجتماعية والتنمية الحماية لمشروع باالعداد االجتماعية الشؤون وزارة تقوم) ثالث مكونات على تصميمه في المشروع يعتمد الخدمات) 1الدولي مراكز دور وتعزيز تطوير

االجتماعية ( الشؤون لوزارة التابعة الشؤون) 2االنمائية وزارة في فاعل وطني برنامج وتعزيز انشاءالمحلية ( التنموية المشاريع لتمويل االسر) 3االجتماعية لدعم الوطني البرنامج ومأسسة متابعة

فقرا االكثر

واالجتماعي البيئي القياس اطار تصميم Environmental amp Social AssessmentتمFramework وضمان المشروع ضمن المقترحة لمشروعات واالجتماعية البيئية االثار لدراسة

المقترح االطار هذا في الواردة واآلليات للسبل وفقا وجدت حال في تجنبها

بغية االطار هذا مناقشة في المعنية الجهات بمشاركة االجتماعية الشؤون وزارة قناعة من انطالقاالغاية لهذه سيعقد الذي االجتماع في المشاركة الى تدعوكم الوزارة فان الرسمي بشكله اقراره

فيه الواقع الجمعة نهار ظهر قبل من العاشرة الساعة عند االجتماعية الشؤون وزارة مقر 25في الثاني 2013كانون

• PROJECT DEVELOPMENT OBJECTIVES
• 12 IMPLEMENTATION
• • Natural Landscape
  • Soil Water and Air Pollution
  • Water Resources
  • Archaeological and Historical Sites
  • 56 Screening of Sub-Projects
  • • 57 The Environmental and Social Screening Process
    • • 6 ENVIRONMENTAL REVIEW PROCEDURES AND GUIDELINES
      • 61 Status of the SPPP Environmental Review
      • 64 Prior to approval the environmental requirements will consist of an assessment of the institutional and legal framework pertaining to the project as well as the development of procedures and guidelines that the PCT will be required to follow after it will receive on the job training during the first month of the project implementation
      • • ANNEX III
        • Terms of Terms of Reference for the preparation of an