(sfdp)...hr hour sfdp social fund for development project hse-mp health, safety and environment...

Republic of Iraq Ministry of Planning

Environmental and Social Management Framework (ESMF)

For

Iraq “Social Fund for Development” Project

(SFDP)

World Bank Group

ESMF Report – 3 February 2019

ESMF – Iraq Social Fund for Development Project -------------------------------------------------------------------------------------------------------------------------------------------------------------------

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Table of Contents List of Tables .......................................................................................................................................................... ii List of Figures ........................................................................................................................................................ ii Executive Summary ............................................................................................................................................... 1 Chapter 1: Introduction ..................................................................................................................................... 15

1.1. Preamble ............................................................................................................................................ 15 1.2. Rationale for preparing ESMF ........................................................................................................ 15

Chapter 2: Project Description .......................................................................................................................... 17 2.1. The Iraqi Social Fund for Development Project (SFDP) ............................................................... 17 2.2. Project Development Objectives (PDOs)......................................................................................... 17 2.3. Project Components .......................................................................................................................... 18 2.4. Budget and Implementation Plan .................................................................................................... 19

Chapter 3: Environmental and Social Settings ................................................................................................ 21 3.1. Physical Environment ....................................................................................................................... 21 3.2. Biological Environment .................................................................................................................... 24 3.3. Socio-economic Characteristics ....................................................................................................... 27

Chapter 4: Policy, Legal, and Regulatory Framework ................................................................................... 32 4.1. National Laws and Regulations ....................................................................................................... 32 4.2. National Environmental Legislations .............................................................................................. 35 4.3. Roles and Responsibilities in the Field ............................................................................................ 40 4.4. Applicable World Bank Policies ...................................................................................................... 40 4.5. Gaps Analysis .................................................................................................................................... 43

Chapter 5: Environmental and Social Impacts Framework ........................................................................... 45 5.1. Risk Identification ............................................................................................................................. 45 5.2. Impact Assessment Methodology ..................................................................................................... 46 5.3. Expected Adverse Impacts – overview ............................................................................................ 47

Chapter 6: Public Consultation and Engagement ........................................................................................... 52 6.1. Stakeholders’ Consultation .............................................................................................................. 52 6.2. Stakeholders’ Participation .............................................................................................................. 57 6.3. Grievance Redress Mechanism (GRM) ........................................................................................... 63

Chapter 7: Environmental and Social Management Framework .................................................................. 69 7.1. Proposed Environmental and Social Mitigation Measures ........................................................... 69 7.2. Environmental and Social Management and Monitoring ............................................................. 72 7.3. Site Visits and Reporting Requirements ......................................................................................... 81

Chapter 8: Institutional Arrangements and Capacity Building ..................................................................... 83 8.1. Institutional and Implementation Arrangements ........................................................................... 83 8.2. Implementation Functions ................................................................................................................ 86 8.3. Capacity Building and Training Needs ........................................................................................... 88

Chapter 9: Screening and Safeguards Instrument .......................................................................................... 91 9.1. Sub-Project E&S Screening and Approval Framework ................................................................ 91 9.2. Cost Estimates ................................................................................................................................... 95

References ........................................................................................................................................................... 96


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Annexes ................................................................................................................................................................ 97 Annex I: Pollutants’ Thresholds ..................................................................................................................... 97 Annex II: Public Consultation Questionnaire & Participants’ List ............................................................ 100 Annex III: Sample Grievance Registration Form ........................................................................................ 113 Annex IV: Environmental & Social Screening Criteria/Checklists ............................................................ 115 Annex V: Typical ESMP report content ....................................................................................................... 119 Annex VI: Environmental Requirements for Contractors ........................................................................... 120

List of Tables

Table 1: SFDP’s Time and Budget Schedules ...................................................................................................... 20 Table 2: Population distribution in Iraqi governorates – 2014 ............................................................................. 28 Table 3: Age distribution in Iraq – 2014 ............................................................................................................... 28 Table 4: Distribution of income and expenditure at per capita and household levels ........................................... 30 Table 5: Amount of social assistance according to family size – Law 11 of 2014 ............................................... 34 Table 6: Roles and responsibilities in the field (including KRG) ......................................................................... 40 Table 7: Summary requirements of the WB's and Iraqi ESMF ............................................................................ 44 Table 8: Summary impacts and rating for this ESMF .......................................................................................... 51 Table 9: Participants of the consultation interviews ............................................................................................. 52 Table 10: E&S impact rating by public consultations – Al Muthanna, Salahiddin & Dohuk .............................. 53 Table 11: Identified stakeholders and most appropriate communication methods and tools ................................ 61 Table 12: Available communication channels for the GRM ................................................................................ 67 Table 13: The proposed GRM roles and responsibilities ...................................................................................... 67 Table 14: Proposed environmental and social mitigation measures ..................................................................... 69 Table 15: Environmental and Social Management and Monitoring Framework .................................................. 74 Table 16: Monitoring and reporting schedule during implementation/ construction phase .................................. 82 Table 17: Proposed training workshops and courses ............................................................................................ 89 Table 18: Potential sub-projects as presented in PAD .......................................................................................... 92 Table 19: Safeguard instruments proposed for the sub-projects identified to date ............................................... 93 Table 20: Safeguarding, approval and disclosure methodology ........................................................................... 94 Table 21: Cost estimates for E&S safeguards instruments (per sub-project) ....................................................... 95

List of Figures

Figure 1: Project Schedule by Governorate .......................................................................................................... 17 Figure 2: Depth of the groundwater in Iraq’s hydrogeological zones (Source: al-Jiburi et. al, 2015) ................. 23 Figure 3: Distribution of Ecoregions in Iraq according to Project areas ............................................................... 25 Figure 4: Age distribution in Iraq – 2014 ............................................................................................................. 28 Figure 5: SFD Governance and Institutional Arrangements ................................................................................. 84 Figure 6: MOP’s Organizational Structure ........................................................................................................... 87 Figure 7: Outline of the E&S Screening and Approval Methodology .................................................................. 92


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List of Acronyms and Abbreviations

°C Degree Celsius LSADs Labor and Social Assistance Department Ag Silver LTTs Local Technical Teams Al Aluminum M Meter APHA American Public Health Association M&E Monitoring and Evaluation ARAP Abbreviated Resettlement Action Plan M&E Monitoring and Evaluation As Arsenic MCM Million Cubic Meters AWWA American Water Works Association MENA Middle East and North Africa B Boron MFIs Micro Finance Institutions Ba Barium min Minute BCM Billion Cubic Meter MIS Management Information System BMPs Best Management Practices MM Man Month BOD Biochemical Oxygen Demand Mn Manganese Br2 Bromine MOA Ministry of Agriculture CaC Calcium Carbide MoEnv Ministry of Environment Cd Cadmium MOF Ministry of Finance CDGs community development groups MOH&

Env Ministry of Health and Environment

CfW Cash for Work MoIM Ministry of Industry and Minerals Cl Chloride MOLS

A Ministry of Labor and Social Affairs

Cl2 Free Chlorine MOP Ministry of Planning CN Cyanide MOT Ministry of Transport CO Carbon monoxide MSF Médecins Sans Frontières Co Cobalt N/A Not Applicable CO2 Carbon dioxide NDP National Development Plan COD Chemical Oxygen Demand NGO Non‐Governmental Organizations Cr Chromium NH4 Ammonium CSO Central Statistical Organization Ni Nickel CSOs Civil Social Organizations NO2 Nitrogen dioxide Cu Cupper NO3 Nitrate CUs Compact Units O2 Oxygen dB(A) A-weighted decibels OHS Occupational Health and Safety DDT Dichlorophyneltrichloroethane OP/BP Operational Procedure/ Bank Policy Dept. Department PAD Project Appraisal Document DO Dissolve Oxygen PAPs Project Affected Persons E&S Environmental and Social Pb Lead EA Environmental Assessment PDOs Project Development Objectives EHS Environmental, Health and Safety pH Used to express acidity EIA Environmental Impact Assessment PM Particulate Matter EMP Environmental Management Plan PM Project Manager ESIA Environmental and Social Impact Assessment PMO Project Management Office ESMF Environmental and Social Management

Framework PMT Project Management Team

ESMP Environmental and Social Management Plan PO4 Phosphate ESSRP Emergency Social Stabilization and

Resilience Project POM Project Operation Manual

F Fluoride PPE Personal Protective Equipment Fe Iron RAP Resettlement Action Plan GHGs Green House Gases RPF Resettlement Policy Framework GOI Government of Iraq’s S2- Sulfide GR Grievance Redress SAP Safeguards Action Plan

GRM Grievance Redress Mechanism SCPP Stakeholder’s Consultation and Participation Plan

GRS Grievance Redress Service SCPRS Supreme Committee for Poverty Reduction Strategy

ha Hectare Se Selenium


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Hg Mercury SFD Social Fund for Development hr Hour SFDP Social Fund for Development Project HSE-MP

Health, Safety and Environment Management Plan

SO2 Sulfur dioxide

IASC Inter‐Agency Standing Committee SO4 Sulfate IBAs Important Birds Areas SSS Safeguards Screening Summary IBRD International Bank for Reconstruction and

Development TOR Terms of Reference

ID Identification Document TSP Total Suspended Particles IDP Internally Displaced People UN United Nations IFC International Finance Corporation US$ United States Dollars ILO International Labor Organization USD United States Dollar IQD Iraqi dinar USGS United States Geological Survey ISIS Islamic State in Iraq and Syria VOCs Volatile Organic Compounds IT Information Technology WB World Bank IUCN International Union for the Conservation of

Nature WBG World Bank Group

KBAs Key Biodiversity Areas WEF Water Environment Federation Km Kilometer WHO World Health Organization KRG Kurdistan Regional Government WTPs water treatment plants KRSO Kurdistan Region Statistics Office Zn Zinc L Liter


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Executive Summary

ES.1 – Introduction

With the recent liberation of Mosul from ISIS, Iraq faces a historic opportunity for national reconciliation through the effective delivery of critical social services, economic growth and recovery programs. The reinstatement of trust between the State and its citizens is highly dependent on the Government of Iraq (GOI) demonstrating its capacity to deliver security, jobs and economic growth to all Iraqis, with a focus on the poor, the vulnerable and the millions of Internally Displaced People (IDP). The GOI has embarked on a comprehensive reform of social protection programs. Two major achievements were the shift from categorical to poverty targeting in social assistance that improved outreach to the poor; and the issuance of the new integrated Social Insurance Law that is likely to have a positive impact on labor mobility and fiscal rationalization of the pension’s fund.

Complementing this work, the GOI, represented by the Ministry of Planning (MOP), requested the World Bank’s support in the design and financing of a Social Fund for Development (SFD) project to support locally driven initiatives to improve the living conditions and opportunities of the poor and most vulnerable in Iraq.

The GOI has demonstrated its commitment and support to the design of this operation and established a high-level national team to guide and coordinate the development and institutionalization of the SFD, as well as five technical teams to work on the different aspects of the fund. These teams developed the design of the SFD, and the draft SFD law. The SFD would thus be established by law, as an autonomous institution that does not operate under civil service regulations. While SFD law is being formulated and issued, the Ministry of Planning (MOP), at the central and local levels, specifically by the Directorate General of Poverty Reduction Strategy, will initiate SFD activities in three governorates in the first year, then expand to another four in the second year, and ultimately scale-up to the rest of the country starting in year three of project implementation.

The Project Development Objectives (PDOs) are to: (1) Improve access to basic services and; (2) Increase short-term employment opportunities, in targeted communities.

Rationale

The Project is classified as Environmental Category "B” according to the provisions of The World Bank’s OP/BP 4.01 (Environmental Assessment). Component 1 of the Project will include sub-projects for implementing rehabilitation works in all target governorates. These sub-projects will target basic essential services of education, health, water, economic infrastructure, and access to markets. However, these activities are small-scale civil works, which are expected to result in minor environmental and social impacts, though site-specific and can be mitigated and managed properly.

To date, the specific activities and exact locations of project interventions have not been determined. However, the World Bank has prepared a Safeguards Action Plan (SAP) which will serve as a roadmap for preparing subsequent safeguard instruments. In addition, a Project Operational Manual has also been developed by MOP.

Therefore, MOP has embarked on preparing an Environmental and Social Management Framework (ESMF) which will provide guidance on: (1) the approach to be taken during project implementation; (2) appropriate safeguard instruments; and (3) a framework for mitigating and monitoring impacts.


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This ESMF document recommends mitigation measures, for environmental and social impacts that may result from the Project’s activities during implementation. The ESMF also includes a screening checklist for the further preparation of simplified Environmental and Social Management Plans (ESMPs) and checklists, institutional arrangements for implementation, the monitoring requirements, the capacity building needs, and the cost estimates, as well as the provisions to exclude Category A‐type sub-projects. A Resettlement Policy Framework (RPF) has been also prepared to address any land taking (either voluntary or involuntary), lost assets, and/or compensation issues according to the provisions of WB’s OP/BP 4.12 (Involuntary Resettlement), and relevant Iraqi regulations. Finally, all prepared safeguards instruments are subject to clearance through Iraqi systems (MOP) as well as by the World Bank’s. Both ESMF and RPF documents will be disclosed in-country and on the World Bank’s external website in line with the relevant World Bank information disclosure policy.

ES.2 – Project Description

The 5-year IBRD-funded Project (SFD) will be implemented by MOP in the first 3 years, but will continue, starting year 4, through the newly established autonomous SFD Institution. The Following are the key three components planned within SFD:

Component 1 – Financing Community Sub-projects

The objective of this component is to improve access of communities to basic services. It will finance subprojects at the local level. This will consist of basic essential services that represent priority investments identified by the community. These will be based on a menu that includes investments that can be realized using labor-intensive techniques and maximizing the use of local materials. The work will start with Muthanna, Salahiddin, and Dohuk during the first year, and expand to Ninawa, Baghdad, Thiqar, and Qadisiya, during the second year, and subsequently to all 18 governorates by year five. The component will finance community level subprojects in education, health, water, small-scale economic infrastructure, and access to markets.

Targeting of communities within selected Nahiyas (local governments) of those governorates will consider the degree of need and the number of potential beneficiaries. Communities will be chosen according to total population size and the level of services accessed by community members.

There are several criteria that determine sub-projects eligibility: subprojects must serve the targeted population, and must illustrate a firm commitment to the active participation and contribution of the beneficiaries equally, in implementation and maintenance/sustainability; and sub-projects must be technically feasible, financially viable and socially justified.

Component 2 – Supporting Microfinance Systems Strengthening

The objective of this component is to support the establishment of the overall MSE program of SFD through technical assistance and capacity building activities. Support will be provided to the Government of Iraq on: (1) enhancing capacity to manage MFIs that will be engaged under the SFD in the future; (2) reviewing the regulatory environment to allow MFIs to function without market distortions; and (3) developing a framework for structured financing that would allow the flow of funds from SFD to MFIs in a sustainable manner, while meeting SFD objectives. The component, once implemented, would allow for capitalization of the MFI sector based on good practices that would ensure: (1) adequate outreach; (2) sustainability; and (3) impact.


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Component 3 – Capacity Building and Institutional Development

This component will provide overall implementation and project management support for the duration of the project, to the establishment and operation of the SFD. This will include: (1) supporting MOP in managing the SFD functions during the establishment phase and project management activities; (2) providing institutional development for the eventual SFD autonomous institution; (3) building the capacity of local government, community groups, and NGOs; and (4) contracting NGOs to undertake social and economic assessments for local communities.

Gender will play a key cross-cutting role to be supported across all components. Gender interventions are expected in the following areas: (1) voice and agency, through inclusion of women at community development groups (CDGs) and at the Board of Trustees of SFD; (2) undertaking gender-sensitive social and economic assessments; (3) holding targeted consultations, trainings and other community gatherings for women; (4) developing community-level gender action plans; (5) increasing access for girls education under the education subprojects; (6) improving access for maternal health care for health subprojects; and (7) inclusion of gender-specific indicators and disaggregated data collection in the Results Framework for monitoring and follow-up.

The Project will have the following positive impacts:

- Investments in agricultural infrastructure will boost agricultural productivity of local farms;

- Improvement in the farming and ancillary roads will increase market accessibility to farm products, generating higher income for farmers;

- Improvements in road connectivity will also lead to a higher volume of goods and services traded between the Project communities and the outside economy, leading to an overall rise in job opportunities and welfare levels;

- Fostering participation of the poor and marginalized citizens (including women) in decision-making process at the community level;

- Providing short-term job opportunities, including for women, people with disabilities, and special needs;

- Rehabilitation and repair of schools will facilitate enrolment of school-aged children in schools, who have missed school years due to violence and displacement;

- Rehabilitation or improvements of health facilities will contribute to efforts to reduce out-of-pocket health expenses by offering preventative care in local health facilities; and

- Building cohesion and social cooperation and enhancing trust and transparency between citizens and the government.

The Project will be implemented in five years. The following is a proposed schedule and budget breakdown for carrying out key components:

Table ES.1: Proposed time schedule and budget for implementing SFDP

Year 1 Year 2 Year 3 Year 4 Year 5 Budget (million USD) SFD Establishment Phase at MOP Autonomous SFD Institution

Component 1: Financing Community Sub-projects 262.00 Dohuk, Salahiddin, Muthanna

Ninawa, Baghdad, Qadisiya, Thiqar

Sulaimaniya, Kirkuk, Erbil, Diyala, Anbar, Babel, Kerbela, Wasit, Najaf, Maysan, Basrah

Y1: 5.27 Y2: 19.70 Y3-5: 237.03

Component 2: Supporting Microfinance Systems Strengthening 3.00


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Policy and Regulatory Support Technical Assistance Capacity Building for MOP/SFD to Managed MFI Operations MIS Systems for MFI Management and Oversight

1.50 0.75 0.75

Component 3: Capacity Building and Institutional Development 30.00 Project Management (including operating costs) SFD Organizational Development Support to Local Government Support to NGOs

14.10 6.20 1.20 8.50

Total 300.00

ES.3 – Environmental and Social Setting

Physical environment:

Iraq has a hot, dry climate characterized by long, hot, dry summers and short, cool winters. January is the coldest month, (5°C to 10°C), and August is the hottest month (up to 30°C and more). The mean maximum temperature in July and August is about 43°C, but during heat waves the temperature shoots up to 49°C. Dust storms are common in summer. High temperature and winds combine to cause very high evaporation, about 10 mm per day during June, July, and August. Two wind types prevail, the Sharqi, a dry, dusty wind with occasional gusts of 80 km/h, from April to early June, and late September through November. And the Shamal, a steady north and northwest wind, occurring from mid-June to mid-September. About 70% of the average rainfall in the country falls between November and March; June through August are often rainless. However, rain could be local to violent storms causing flooding.

Air quality in most areas is an issue, mostly caused by mobile sources, industrial activities, and private generators. High numbers of vehicles, waste burning, cutting trees, industries and oil sector, as well as lacking proper treatment systems are key causes, among others. Green House Gases (GHGs) emission rates in general, and Methane, in particular, are increasing from year to year. Noise is also an issue, which is linked to vehicular traffic, especially in highly urbanized areas.

Water is mostly available through abstraction from groundwater basins, from north to south along Tigris and Euphrates, poor water quality is observed though. Disposal of wastewater in rivers are among the greatest factors for decreasing quality. Water per-capita ranges between 110 to 460 L/ day. However, water treatment services do not currently reach all Iraqis. In 2016, approximately 86% of the urban population and approximately 66% of the rural population have access to an improved water source via the country’s water distribution network. Artesian water wells have been widely drilled to support the water needs for agriculture.

Iraq is estimated to produce 31,000 tons of solid waste every day with per capita waste generation exceeding 1.4 kg per day. Solid waste mismanagement problems remain also of great concern, as systems are very old, and collection services are only limited to urban areas within the municipality administrative boundary, in addition to the poorly engineered landfills.

Biological Environment:

There are several primary and secondary ecoregions belonging to the Palearctic Realm that make up the terrestrial ecosystems of Iraq. The five primary ecoregions that make up the bulk of Iraq include:

− Tigris‐Euphrates alluvial salt marsh; − Arabian Desert and East Sahero‐Arabian Xeric Shrublands;

https://www.weatheronline.co.uk/Iraq.htm

https://www.weatheronline.co.uk/cgi-bin/regframe?3&PRG=cityklima&WMO=40650&INFO=0&PAG=1


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− Mesopotamian Shrub Desert; − Middle East Steppe; and − Zagros Mountains Forest Steppe.

The Lower Tigris and Euphrates River Basins are among the most important wetland ecosystems of the world for the extensive network of marsh habitats that form at their southernmost end. The system also contains large reservoirs with many designated Important Birds Areas. Lakes of Darbandikhan, Mosul, Tharthar, and Razzaza are well-known in this regard. The Tigris River is one of the largest rivers of the Middle East stretching for over 1,900 km, of which 1,415 km are within Iraq. While, The Euphrates River is formed by the confluence of two rivers: the Karasy River and the Murad River. The total length of the Euphrates River from the source of the Murad River to its confluence with the Tigris River is 2,940 km, 1,159 km of which runs within Iraq.

Fauna is gaining more importance by national and international agencies. The Birds of Iraq include 417 bird species of which 182 are passage migrants and an additional 27 are vagrant. Of these, 18 species are of conservation concern, the majority of which are either possible or confirmed breeders. Some 106 species of fish (including freshwater and marine entrant species) have now been recorded in the non‐marine waters of Iraq and of these 53 species are marine fish. Little information exists on other globally important fauna species of insects, amphibians, reptiles, and mammals.

As for Flora, The Tigris‐Euphrates ecoregion’s vegetation is dominated by aquatic plants such as reeds. Vegetation of the Arabian Desert and East Saharo‐Arabian Xeric Shrublands has received almost no study in recent years. Several uniquely adapted plants are likely to exist in Mesopotamian Shrub Desert ecoregion. In the Middle East Steppe ecoregion, herbaceous and dwarf shrub sage brush communities are important grassland habitats, and during summer many Bedouin can be seen bringing their herds northward to take advantage of the spring and summer grazing.

Socio-economic characteristics:

The population of Iraq is around 39 million according to estimations in 2018, with a population growth rate of 2.5%. Group ages (0-9, and 10-19) are the largest proportions of the community. Females comprise almost half of the population. In 2016, the percentage of woman-headed households was 10.5% at the national level. Terrorist operations, eviction, and displacement have affected women in particular. This has resulted in a big number of women either widowed or divorced in their dependent households. Last conflicts have severely affected all vulnerable groups as well, including, women/girls, the elderly, and children, leaving almost 51% women displaced. Post-conflict consequences have posed a greater challenge against development.

In 2014 unemployment among men was 8.4%, while among women, it was 21.9%. However, unemployment rate was peaking in the age group 15-19 which amounted to 24.5%, while lowest rate was found at 2.9% among the age group 60-64.

Many programs for rehabilitation, microfinance, and income-generating projects have started following last crises. Within the working category of the community, only 14% are female, which is far below labor force participation in the Middle East and North Africa (MENA) Region of 22%. Unemployment had risen to 10.8% in 2016, compared to 10.6% in the preceding year. There is a large variation in the rates of underemployment in Iraq at the provincial level. This can be explained by the different nature of work and economic activities prevailing in each province.


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The average per-capita monthly income of Iraq at the market price was 330.3 thousand IQD, according to the semi-annual social and economic survey for 2014. However, at the household level, average income was 1,875.4 thousand IQD, and average expenditure was 1,960.7 thousand IQD. In areas controlled by ISIS, poverty increased from 19% by end of 2013 to 41% in 2014.

As for, child labor, the proportion of children who were engaged in work between the ages of 6-14 years, reached 3.5% of the number of children within this age group. 70% of displaced children missed a full school year. Net enrollment rates in primary education (6-11 years) in public, civil and endowment schools was highest in Baghdad (97%). While the lowest enrollment rate was recorded at (72%) in Anbar, for the same year.

ES.4 – Policy, Legal, and Regulatory Framework

A set of relevant Iraqi legislations was identified for the implementation of different components of the SFDP. Other standards concerning the monitoring of air quality, noise, and discharges to water bodies were found useful throughout implementation. These were appended to the main report of ESMF. The following is a quick review into applicable legislations:

- Constitution of Iraq - The Ministry of Planning, Law no. 19 – year 2009 - The National Development Plan, 2018 – 2022 - Economic Empowerment through Income Generating Projects, Law 10 – 2012 - Social Protection Law no. 11 of 2014 - Labor Law no. 37 – 2015 - Acquisition Law no. 12 – 1981 - Public Health Law no. 89 – 1981 - Public Health Law / Safe storage and handling of chemicals, instructions no. 4 – 1989 - Protection and Improvement of the Environment Law no. 27 – 2009 - Environmental Protection and Improvement in Kurdistan Region, Law no. 8 – 2008 - Protection of Wild Animals and Birds, Law no. 21 – 1997 - Forest Law no. 30 – 2009 - Decision Concerning the Cutting of Trees no. 1 – 1991 - Preservation of Water Resources Regulation no. 2 – 2001 - Protection of Ambient Air Quality Regulation no. 4 – 2012 - The new determinants for the Prevention of Pollution of Rivers and Public Water Regulation,

no. 25 – 1967 - Antiquities and Heritage Law no. 55 – 2002 - Environmental Assessment – Establishing the Ministry of Environment Law No. 37 – 2008 - EIA categorization – Environmental Criteria for Carrying out Projects and Monitoring

Appropriateness of Implementation Instructions no. 3 – 2011

The main report of ESMF has also provided key responsibilities of different public entities at the governorate level pertaining to the implementation of the Project

Table ES.2: Responsibility matrix for field implementing

Department Key roles and responsibilities 1. Iraqi Ministry of Health and Environment 2. Board for the Protection of the Environment at KRG

- Determination of level of EIAs required for sub-projects - EIA/ EMP review - Issuance of environmental permits


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Department Key roles and responsibilities 1. local councils for protection and improvement of the environment 2. Environment protection councils at KRG governorates

Perform field inspections and monitor actual implementation of Environmental Management Plans (EMPs) on the ground, as well as apply a fine system against environmental violations

1. Environment Protection and Improvement Council. 2. Environmental protection and improvement committee at governorates of the KRG

Coordination between local environment protection councils and authorities (municipalities, governorates, labor and social directorates, etc.)

Health Directorates (central government and KRG)

- Monitor communicable diseases - Provide vaccinations to workers and the hosting communities, - Provide medical care to all community members through local

health care centers and programs - Provide awareness programs to communities

Labor and Social Affairs Directorates (central government and KRG)

- Overseeing local labor markets - Monitoring violations to labor according to the labor law - Field inspection for illegal workforce (including child labor) - Field inspection for Occupational Health and Safety measures - Processing applications for various assistance programs (job

opportunities, livelihood assistance, microfinance, cash support, etc.)

The following are operational policies of the World Bank triggered for the Project, in addition to other useful references for financing investment projects, access to information, and occupational health and safety:

- Investment Project Financing, OP/BP 10.00 - The World Bank Policy on Environmental Assessment – OP4.01 - Physical Cultural Resources, OP/BP 4.11 - Involuntary Resettlement, OP/BP 4.12 - The World Bank Policy on Access to Information - IFC’s Environmental Health and Safety Guidelines – 2008

Key gaps between the National and the Bank’s legislations are related to the following areas:

- Requirements and provisions for preparing ESMF/ESMP - Requirements for carrying out public consultations - Involuntary resettlement - Information disclosure

ES.5 – Public Consultation

The following have been consulted using a pre-designed questionnaire in Arabic language. The approach of conducting individual interviews was selected for security reasons, and because of the widely-spread geography of Project boundaries. Local directorates of the MOP have played a significant role in reaching out to target districts and even scaling down to Nahiyas and smaller villages.


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Table ES.3: Public consultation participants

Area Date(s) of interviews Number of participants Al Muthanna governorate, Al-Warka’ District + Al-Helal Nahiya

14-18 Dec 2018 141

Salahiddin, Al-Alam District

14-18 Dec 2018 115

Dohuk governorate, Baadre Nahiya + Bebava village/ Qusrok Nahiya

23 – 29 Jan 2019 123

The questionnaire included enough information on the Project’s components, activities, and positive impacts, nevertheless, MOP’s staff were able to explain the Project in more detail, including benefits foreseen, and the questions part, which was related to a number of environmental and social/socio-economic expected aspects (the Full Report includes a copy of the questionnaire, see annex II).

In summary, feedback from the participants showed a good level of confidence and optimism towards implementing the proposed activities of the SFDP. Most of the feedback has already predicted minor negative impacts on physical, biological, and cultural environments, community health, workers’ safety, working conditions, and site hygiene during implementation, in addition to engaging vulnerable/ marginalized groups in rehabilitation opportunities. However, participants seemed to be a bit concerned about how fair targeting and selection of beneficiaries of the project would be. Along with some expected issues in market prices, local market participation, and paying back micro loans. Higher concerns were observed with regard to labor influx, and the possibility to increase nuisance/ disturbance in the neighborhood as a result of carrying out rehabilitation activities. Most importantly, interviewees showed little concerns about involuntary taking of land, or encroachers’/IDPs’ being displaced from occupied properties for the implementation of the Project (if any), though unfair compensation in return for loss of assets or access to livelihood means and resources could be an issue.

Stakeholder participation

The Stakeholders’ engagement throughout the Project implementation is quite critical; to ensure achieving positive impacts and to ensure complaining channels are accessible. The stakeholders’ engagement plan should start by identifying stakeholders. This essentially include all people and groups directly or indirectly affected by the Project, people and groups who may take part in implementation, and those who possibly would influence and make decisions on implementation, as well as people and groups who have interest in the Project. These are collectively referred to as Project Affected Persons (PAPs). Of particular importance, vulnerable groups should be identified in the early stage of the Project, and those should essentially include youth, the unemployed, women, children, the elderly, and people with special needs and disabilities.

Consultations, including vulnerable groups should be conducted for small-scale civil work interventions of Component 1 before and during construction phase. Communication with stakeholders should be ongoing (i.e. apply to all phases of implementation). Communication channels with PAPs may include group meetings, individual meetings, social media, project leaflets and notice boards/ bulletins, as well as emails, telephone, and official correspondence.

Grievance Redress Mechanism (GRM)

The proposed GRM for the SFDP aims to resolve issues that could come across implementation promptly, more efficiently, and accurately. The design of the GRM system should provide means for


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collecting supportive documents and evidences, investigating the problem, and supporting the final decision. An effective GRM is characterized by: diversity, clear procedures, swift responses, and allowing for two-way communication.

Complainants would commonly approach this GRM for many reasons, including those related to incomplete or no service, vague procedures, inappropriate/ unfair treatment by the staff, and harm (environmental and/or social) to individuals or groups as a result of carrying out the Project’s interventions.

The complaint/ grievance, once received, should be promptly resolved or undergone further investigation. Complaints are sorted out according to complexity. Direct responses should be given to simple inquiries by concerned staff members in 3-6 working days as a maximum, and should be documented and archived as per the relevant procedure. While, more comprehensive measures should be applied to complex issues, including field investigation and communicating with higher management for final decisions within a timeframe of 20 working days as a maximum. After the completion of the proceedings, the complaint is closed, and information is included in the system, including the action(s) taken and the result(s) required. The complainant shall be notified of the result and the action immediately and informed of the possibility of objecting to the procedure. See detailed procedures in the main ESMF report.

In addition to PMO, the MOP, project offices in governorates, and Community Development Groups (CDGs), the World Bank’s Grievance Redress can also be approached for reporting and resolving issues.

ES.6 – Environmental and Social Impact and Management Framework

The overall risk ranking of the SFDP for environmental and social aspects is “Substantial”, mostly due to social risks. For Component 1, the key social challenges are associated with the process of identification and selection of working groups in their areas, the effective representation and participation especially for the underprivileged subpopulations, the perception of unfair distribution of services, and eventually what could be achieved for regaining trust with the government. Other risks are operational ones, like delays in implementing subproject activities and poor quality. And risk of lacking security in project areas. Additionally, risks can be related to involuntary taking of land during project implementation and lack of compensation for project affected persons (PAPs), though low and temporary in nature. Furthermore, risks may include the potential of child/forced labor or issues connected to labor influx.

On another hand, environmental risks are considered low, and can be related to: working in heights, exposure to working materials, either for cleaning, painting, or even exposure to working tools, and hard/ sharp objects; community health and safety; contamination of the physical environment (dust, noise, runoffs, waste, etc.); endangering the biological sensitive environments; as well as the risk of damaging cultural/ historical heritage, including chance finds.

The following provides summary impacts and management measures.

Table ES.4: E&S Impact and management framework

Impacts Rating Management

Component 1: Financing Community Sub-projects Health and safety impacts 1 Occupational Moderate, - Avoid manual transfer of big quantities of materials and heavy


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health and safety issues

direct, and in the short term

equipment - Implement administrative controls into work processes,

including offering enough time and suitable conditions for resting

- Implement good house-keeping practices, and clean debris and spills regularly

- Locate electrical cords and ropes in common areas and marked corridors

- Train on and use proper scaffolding systems and personal fall arrest systems

- Use suitable Personal Protective Equipment (PPE), including helmets, vests, gloves, masks, and hard boots where necessary

- Check equipment for electrical loos, and apply maintenance only through specialized persons

- Use electricity-specific PPE where needed - Avoid assigning tasks to unskilled workers where special

expertise is required - Provide on-the-job training programs to complement any

deficiency

2 Community health and safety issues

Moderate, direct, and in the short term

- Provide surveillance and active screening, and immunization - Provide treatment on-site or in community health care

facilities - Eliminate unusable impounded water, and apply vector control

programs - Erect suitable and adequate warning signage along culvert

cleaning and excavation sites - Collaborate with local communities and responsible authorities

to improve signage and visibility - Avoid uncovered piles of aggregates and other construction

materials - Avoid burning waste in worksites - Avoid or minimize driving through community areas and

dangerous routes during daytime - Alert drivers on local speed limits, and monitor

implementation - Minimize traffic by purchasing from the local markets to the

extent possible

Environmental impacts 3 Pollution of the

surrounding environment

Moderate, direct, and indirect, and in the medium to long term

- Identify available waste collection and treatment programs - Identify opportunities for reducing, reusing, and recycling

waste - Put procedures and operational controls for on-site storage - Segregate and pre-treat oil and sediment/grease-containing

effluents - Discharge to sanitary network only after confirming

compliance - Monitor groundwater quality that could exist close to the


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working areas to ensure compliance - Minimize steepness of slopes to reduce runoffs, including

providing for drainage - Re-vegetate if applicable - Modify/ suspend activities during extreme rainfall and high

winds

4 Endangering biological life

Moderate, direct and indirect, in the medium to long term

- Ensure full adherence to the zero-discharge criterion - Oblige by legal transportation and dumping of materials in

their pre-designated and approved dumpsites - Stay in contact with the concerned authorities for accidental

events - Raise awareness on the importance of natural life

Cultural heritage impacts 5 Possible damage to

objects of historical/ cultural value

Moderate, direct, and in the short term

- Make workers aware of the significance and legal liabilities - Put simple and clear instructions for workers in response to

chance finds - Liaise with responsible authorities - Suspend excavation work and promptly communicate any

chance finds to the responsible authorities

Socio-economic impacts 6 Unfair

representation of the underprivileged/ disadvantaged subgroups

Moderate, indirect, and in the medium term

- Provide adequate level of representation to vulnerable groups in the field through engaging suitable and experienced NGOs and/or CSOs

- Ensure views of vulnerable groups are taken into consideration in planning for work packages

- Provide open and effective channels for addressing complaints (GRM)

7 Social/community conflict and insecurity

Moderate, both direct and indirect, in the short term

- Ensure work packages are within highest development priorities

- Ensure fair distribution of work packages/ job opportunities within areas of need

- Ensure work packages are adequately consulted on and endorsed by community/ tribal leaders

- Ensure enough levels of security onsite - Provide open and effective channels for addressing complaints

(GRM)

8 Worker-related issues

Moderate, direct, and indirect, and in the short term

- Increase control over labor market, by regular inspections - Put more stringent employment terms and conditions on

contractors, and business owners - Provide open and effective channels for addressing complaints

(GRM) - Enforce punishment against violations

9 Labor influx issues Moderate, direct, and in the short term

- Select working places far enough from populated areas - Regulate working hours, and provide clear instructions on

movement around the area


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- Laborers should be subjected to health monitoring, including vaccination where necessary

- Consider local participation while planning for different work packages, with help from relevant NGOs and CSOs

10 Discrepancy/ poor selection for jobs based on ethnicity, religion, culture, physical fitness, gender, age

Moderate, indirect, and in the medium and long term

- Monitor through unannounced visits, field reporting, and pursuing advice from program management

- Adopt a mixed targeting approach, by considering poorest locations with highest numbers of potential beneficiaries, IDPs, and returnees

- Assess the poor under existing databases at MOP and MOLSA.

- Ensure a proper complaining system and corrective measures in place

11 Land acquisition-related issues

Minor, direct, indirect, and in the short term

- The World Bank Policy on Social Safeguards ‐ OP/BP 4.12 (Involuntary Resettlement) will be triggered as a precautionary measure

- Preparation of Resettlement Action Plan/ Abbreviated Resettlement Action Plan according to OP/BP 4.12

- Establishment and operation of a Grievance Redress Mechanism (GRM)

12 Lack of/ insufficient compensation for Project Affected Persons (PAPs)

Moderate and direct, in the short and medium terms


- Preparation of Resettlement Action Plan/ Abbreviated Resettlement Action Plan, including compensation plans, according to provisions of OP/BP 4.12


Component 2: Supporting Microfinance Systems 13 Inflation and price

distortion in local markets

Moderate, indirect, and in the long term

- Ascertain wage rates for skilled and unskilled labor in cooperation with government, community leaders, and/or local business people

- Keep wages lower than the market rate in order to mostly attract economically disadvantaged individuals

- Survey the local economy on a regular basis throughout the project, to ensure appropriate levels of wages

- Consult other implementing agencies for similar businesses (i.e. CfW wage structures), to reduce disputes between communities of the same territory

- Make pay rates/ modalities clear enough to the beneficiaries

14 Poor supplies and poor demands for products and services in businesses’ locations

Moderate, indirect, and in the medium and long terms

- Limit chain supplies to the local market as much as possible - Provide enough promotional information for beneficiaries

when they approach responsible authorities/ directorates - Increase marketing campaigns for local products through

available media

15 Increasing debt Moderate, - Provide technical advice for business owners/ seekers


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burden, fail to generate sufficient income to support their families, and pay back the loan

direct, and in the medium to long term

- Provide enough means for marketing - Enable relaxed and simplified/ facilitated procedures for

debtors to pay back the loan

Institutional Arrangements

Implementation responsibilities will lie within MOP during the first 2 years. Guidance will be provided by the Supreme Committee for Poverty Reduction, while centrally, the Directorate of Poverty Reduction will assume direct implementation responsibility. During this period, a Project Management Team will be established, and supported with existing resources mostly, thus forming a Project Management Office (PMO). However, several governorate offices will carry out implementation at the local level.

The PMO will be staffed with necessary resources, including for management, procurement, financial, communication, M&E, as well as for environmental and social safeguarding. Responsibilities will include ensuring sustainability of operations and maintenance, providing guidance to community groups, and Monitoring and Evaluation.

In the field, more engineers will come onboard to oversee implementation of E&S safeguards. Additionally, contractors will hire enough environmental and social specialists to prepare compliance reports.

Upon establishment of the SFD institution, a board of trustees will be established, in addition to SFD governorate offices, community development groups, and engagement of Non-governmental Organizations for facilitation.

Training needs

- ESIA/ ESMP requirements and preparation/ sub-project screening/ disclosure - Overview of the ESMF structure, including list of positive subprojects - Mitigation and Monitoring measures, implementation and reporting - Targeting and selection techniques, and record keeping - Public consultation, design, and operation of complaining systems - Best Management Practices onsite, environmental, social, and occupational - Procurement of services and goods

Screening tools and safeguards instrument

As a general rule, No detailed/full ESIA is expected to be required, as activities are most probably screened as Category B. Nevertheless, No category A‐type sub-projects are allowed within this SFDP, and No sub-projects that would trigger any safeguard policy not triggered under the project are allowed as well. The following are the proposed screening tools:

- Monitoring ESMP Checklist: for sub-projects resulting in relatively low-significance environmental and social impacts. The checklist represents the minimum E&S requirements during the implementation phase

- Site-specific ESMP: for sub-projects resulting in relatively medium-significance environmental and social impacts


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- Site-specific ESIA: for sub-projects resulting in relatively high-significance environmental and social impacts

- ARAP/RAP: for sub-projects and activities resulting in temporary and/or permanent resettlement, and land taking activities

The Bank will then review the screening results and accordingly the safeguards relevant instruments shall be confirmed, prepared, consulted with stakeholders and disclosed. Following clearance of the safeguards instruments by the Bank and/or GOI, the ESMPs shall be implemented, supervised and monitored.


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Chapter 1: Introduction

1.1. Preamble With the recent liberation of Mosul from ISIS, Iraq faces a historic opportunity for national reconciliation through the effective delivery of critical social services, economic growth and recovery programs. The reinstatement of trust between the state and its citizens is highly dependent on the Government of Iraq (GOI) demonstrating its capacity to deliver security, jobs and economic growth to all Iraqis, with a focus on the poor, the vulnerable and the millions of internally displaced people (IDP) impacted by the war against ISIS. Time will be of the essence for the government to address the humanitarian needs of the thousands of people living in the areas recently liberated from conflict. Providing this population with livelihood opportunities and rapid employment will be critical in addition to recovery and rebuilding social cohesion.

The GOI has embarked on a comprehensive reform of social protection programs that introduced significant improvements to the existing system by promoting equity, resilience and opportunities for the Iraqi people. Through the World Bank Iraq Emergency Social Protection Support Program – Phase I (P099295), the GOI has developed and progressed in the implementation of the Social Protection Strategic Roadmap 2015-2019, with the vision of having “a comprehensive social protection system for Iraq covering social safety nets, social insurance, and labor market policies”. Two major achievements were the shift from categorical to poverty targeting in social assistance that improved outreach to the poor; and the issuance of the new integrated Social Insurance Law that is likely to have a positive impact on labor mobility and fiscal rationalization of the pension’s fund.

Complementing this work, the GOI requested the World Bank’s support in the design and financing of a Social Fund for Development (SFD) project to support locally driven initiatives to improve the living conditions and opportunities of the poor and most vulnerable in Iraq. Since early 2017, the World Bank has worked closely with senior decision makers in Iraq and provided broad guidance on the conceptual framework based on international good practices relevant to the Iraq context. The SFD will be a platform for mobilizing resources for communities to undertake locally driven initiatives.

The GOI has demonstrated its commitment and support to the design of this operation and established a high-level national team to guide and coordinate the development and institutionalization of the SFD, as well as five technical teams to work on the different aspects of the fund; namely: (1) Governance, Institutional, and Legislation; (2) Financing and International Cooperation; (3) Civil Society Organizations (CSOs) and Community Engagement; (4) Operations and Implementation; and (5) Monitoring and Evaluation. These teams developed the design of the SFD, and the draft SFD law. The SFD would thus be established by law, as an autonomous institution that does not operate under civil service regulations. While SFD law is being formulated and issued, the Ministry of Planning (MOP), at the central and local levels, specifically by the Directorate General of Poverty Reduction Strategy, will initiate SFD activities in three governorates in the first year, then expand to another four in the second year, and ultimately scale-up to the rest of the country starting in year three of project implementation.

1.2. Rationale for preparing ESMF The Project is classified as Environmental Category "B” according to the provisions of The World Bank’s OP/BP 4.01 (Environmental Assessment). The safeguards instruments for this project are prepared in line with the emergency procedures defined by Paragraph 12, Section III, of the Bank


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Policy: Investment Project Financing (Projects in Situations of Urgent Need of Assistance or Capacity Constraints).

Component 1 of the Project will include sub-projects for implementing rehabilitation works in all target governorates. These sub-projects will target basic essential services of education, health, water, economic infrastructure, and access to markets. These investments are local-driven, and will be designed in close coordination with assigned NGOs and the implementing entity (MOP). However, these activities are small-scale civil works, which are expected to result in minor environmental and social impacts, though site-specific and can be mitigated and managed properly.

To date, the specific activities and exact locations of project interventions have not been determined. As the project is being prepared under OP10.00, Paragraph 12, a deferral of preparation of safeguard documents has been requested until the start of implementation. To that end, the World Bank has prepared a Safeguards Action Plan (SAP) which will serve as a roadmap for preparing subsequent safeguard instruments. In addition, a Project Operational Manual has also been developed by the Borrower (MOP).

Therefore, the Project proponent has embarked on preparing an Environmental and Social Management Framework (ESMF) which will provide guidance on: (1) the approach to be taken during project implementation; (2) appropriate safeguard instruments; and (3) a framework for mitigating and monitoring impacts.

This ESMF document recommends specific mitigation measures for environmental impacts that may result from the Project’s activities during implementation. The ESMF also includes a screening checklist against which each sub-project will be screened, and accordingly subsequent environmental and social assessment instruments ‐ such as a simplified Environmental and Social Management Plan (ESMP) and checklists, will be prepared and implemented ‐if required before the commencement of any physical activities of the sub-projects. Additionally, this ESMF document includes institutional arrangements for the implementation of mitigation measures, the monitoring requirements, the capacity building needs, and the cost estimates, as well as the provisions to exclude Category A‐type sub-projects, and those that would trigger any safeguard policy not triggered under the Project. It is quite important to have site-specific ESMPs cleared through the Iraqi Environmental Impact Assessment (EIA) system but fulfilling the requirements of WB’s OP/BP 4.01 at the same time. Where applicable, the more stringent provisions of the WB’s safeguards instruments will be adopted. The ESMF will be disclosed in-country and on the World Bank’s external website in line with the relevant World Bank disclosure policy.

The Project is also expected to have minor socio-economic impacts that will require mitigation measures to account for resettlement (either voluntary or involuntary) and compensation thereof (if applicable). A Resettlement Policy Framework (RPF) has been prepared to address any resettlement and/or compensation issues according to WB’s OP/BP 4.12 (Involuntary Resettlement) and will be implemented prior to commencement of any investment activities


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Chapter 2: Project Description

2.1. The Iraqi Social Fund for Development Project (SFDP) The Iraqi Social Fund for Development Project (SFDP) is a 5-year project funded by the International Bank for Reconstruction and Development (IBRD), and implemented by the Government of Iraq (GOI) through the Ministry of Planning (MOP) during the first 3 years. But will continue, starting year 4, through the newly established autonomous SFD Institution.

The SFD will scale-up across all of Iraq over a period of five years starting in February 2018, using a phased approach. The Fund will begin with three governorates, and expand to seven by year two, and subsequently to all 18 governorates by year five (see the Figure below). The program will support community-level social and economic infrastructure, utilizing labor intensive works, while strengthening the Micro Finance Institutions (MFIs) sector to eventually support micro- and small-enterprise development under the SFD. Capacity building will be embedded in the project for the establishment and management of the SFD, and for local government, communities, micro-finance sector, and related NGOs.

Figure 1: Project Schedule by Governorate

2.2. Project Development Objectives (PDOs) The Project Development Objectives (PDOs) are to: (1) Improve access to basic services and; (2) Increase short-term employment opportunities, in targeted communities.


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This will be achieved through an adaptive approach of: (1) financing for community level subprojects in education, health, water, small-scale economic infrastructure, and access to markets; (2) enhancing capacity of microfinance institutions (MFIs) to support micro and small enterprise (MSE) development; and (3) provision of technical assistance and capacity building.

The PDO level results indicators are:

− Households benefitting from improved access to basic services; − Beneficiaries of short term employment, of which women

The SFDP will have a wide range of positive impacts to the Iraqi affected communities, which include, inter-alia:

− Investments in agricultural infrastructure will boost agricultural productivity of local farms − Improvement in the farming and ancillary roads will increase market accessibility to farm

products, generating higher income for farmers − Improvements in road connectivity will also lead to a higher volume of goods and services

traded between the Project communities and the outside economy, leading to an overall rise in job opportunities and welfare levels

− Fostering participation of the poor and marginalized citizens (including women) in decision-making process at the community level

− Providing short-term job opportunities, including for women, people with disabilities, and special needs

− Rehabilitation and repair of schools will facilitate enrolment of school-aged children in schools, who have missed school years due to violence and displacement

− Rehabilitation or improvements of health facilities will contribute to efforts to reduce out-of-pocket health expenses by offering preventative care in local health facilities

− Building cohesion and social cooperation and enhancing trust and transparency between citizens and the government

The Project will have three components as following:

2.3. Project Components Component 1 – Financing Community Sub-projects

The objective of this component is to improve access of communities to basic services. It will finance subprojects at the local level. This will consist of basic essential services that represent priority investments identified by the community. These will be based on a menu that includes investments that can be realized using labor-intensive techniques and maximizing the use of local materials. The work will start with Muthanna, Salahiddin, and Dohuk during the first year, and expand to Ninawa, Baghdad, Thiqar, and Qadisiya, during the second year, and subsequently to all 18 governorates by year five. The component will finance community level subprojects in education, health, water, small-scale economic infrastructure, and access to markets.

Targeting of communities within selected Nahiyas (local governments) of those governorates will consider the degree of need and the number of potential beneficiaries. Communities will be chosen according to total population size and the level of services accessed by community members. The objective of the targeting scheme is for the SFD to reach out to the most deprived communities that hold a substantial number of people for the program to reap economies of scale. The candidate


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indicators for the level of service provision will include factors such as electrification rate, percent of households served by safe drinking water, school enrolment rate of school age children, percentage of households with access to health services, connection to paved roads and irrigation networks, and availability of job opportunities in the area.

There are several criteria that determine sub-projects eligibility: subprojects must serve the targeted population, and must illustrate a firm commitment to the active participation and contribution of the beneficiaries equally, in implementation and maintenance/sustainability; and sub-projects must be technically feasible, financially viable and socially justified. The work will begin in specific sectors, such as education, health, agriculture and irrigation, and access to markets.

Component 2 – Supporting Microfinance Systems Strengthening

The objective of this component is to support the establishment of the overall MSE program of SFD through technical assistance and capacity building activities. Support will be provided to the Government of Iraq on: (1) enhancing capacity to manage MFIs that will be engaged under the SFD in the future; (2) reviewing the regulatory environment to allow MFIs to function without market distortions; and (3) developing a framework for structured financing that would allow the flow of funds from SFD to MFIs in a sustainable manner, while meeting SFD objectives. The component, once implemented, would allow for capitalization of the MFI sector based on good practices that would ensure: (1) adequate outreach; (2) sustainability; and (3) impact.

This component - and the decision to support the growth of the MFI market via the SFD – is based on considerations of priority and feasibility. Given the current state of development of the financial sector, actions needed to revive economic activity at the micro and small enterprise level, are not easily taken up by the Central Bank, commercial banks or other non-banking financial institutions that are the more likely drivers of MFI development.



Gender will play a key cross-cutting role to be supported across all components. Gender interventions are expected in the following areas: (1) voice and agency, through inclusion of women at community development groups (CDGs) and at the Board of Trustees of SFD; (2) undertaking gender-sensitive social and economic assessments; (3) holding targeted consultations, trainings and other community gatherings for women; (4) developing community-level gender action plans; (5) increasing access for girls education under the education subprojects; (6) improving access for maternal health care for health subprojects; and (7) inclusion of gender-specific indicators and disaggregated data collection in the Results Framework for monitoring and follow-up.

2.4. Budget and Implementation Plan The following Table, shows the 5-year Project phases, components, and timeframe, in addition to a primary budget breakdown.


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Table 1: SFDP’s Time and Budget Schedules


Component 1: Financing Community Sub-projects 262.00 Dohuk, Salahiddin, Muthanna

Ninawa, Baghdad, Qadisiya, Thiqar

Sulaimaniya, Kirkuk, Erbil, Diyala, Anbar, Babel, Kerbela, Wasit, Najaf, Maysan, Basrah

Y1: 5.27 Y2: 19.70 Y3-5: 237.03

Component 2: Supporting Microfinance Systems Strengthening 3.00 Policy and Regulatory Support Technical Assistance Capacity Building for MOP/SFD to Managed MFI Operations MIS Systems for MFI Management and Oversight

1.50 0.75 0.75

Component 3: Capacity Building and Institutional Development 30.00 Project Management (including operating costs) SFD Organizational Development Support to Local Government Support to NGOs

14.10 6.20 1.20 8.50

Total 300.00


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Chapter 3: Environmental and Social Settings

3.1. Physical Environment Climate

Iraq has a hot, dry climate characterized by long, hot, dry summers and short, cool winters. The climate is influenced by Iraq's location between the subtropical aridity of the Arabian Desert areas and the subtropical humidity of the Persian Gulf. January is the coldest month, with temperatures from 5°C to 10°C, and August is the hottest month with temperatures rising up to 30°C and more.

In most of the areas, summers are warm to hot with mostly sunshine. In Baghdad – for example – it is arid with very hot and completely dry summers and cold winters having some rain. The mean maximum temperature in July and August is about 43°C, but during heat waves the temperature shoots up to 49°C. Dust storms are common in summer. High temperature and winds combine to cause very high evaporation, about 10 mm per day during June, July, and August. The winter is chilly with mean minimum temperature of 4.5°C in December and January but the minimum temperature drops to -7°C during cold waves which are experienced intermittently during December and January. In other areas of the Project boundaries, climate is almost similar, daily temperatures can be very hot and heat exhaustion is very likely. As the area is bordered by deserts mostly in the west, hot, dry desert winds can be very strong sometimes, and can cause violent sandstorms.

The summer months are marked by two kinds of wind phenomena. The southern and southeasterly Sharqi, a dry, dusty wind with occasional gusts of 80 kilometers per hour, occurs from April to early June and again from late September through November. It may last for a day at the beginning and end of the season but for several days at other times. This wind is often accompanied by violent dust storms that may rise to heights of several thousand meters and close airports for brief periods. From mid-June to mid-September the prevailing wind, called the Shamal, is from the north and northwest. It is a steady wind, absent only occasionally during this period. The very dry air brought by this Shamal permits intensive sun heating of the land surface, but the breeze has some cooling effect.

About 70% of the average rainfall in the country falls between November and March; June through August are often rainless. Rainfall varies from season to season and from year to year. Precipitation is sometimes concentrated in local, but violent storms, causing erosion and local flooding, especially in the winter months.

There are 40 meteorological stations installed and operated across Iraq. More specific meteorological data on a governorate level can be retrieved by contacting the Iraqi Meteorological Organization and Seismology/ Ministry of Transport (www.meteoseism.gov.iq) or approaching global weather information portals for areas close to the geographical location of the sub-project (see: https://geographic.org/global_weather/iraq/index.html#B).

However, data found may not cover the time period desired for a given site, therefore, onsite measurements should be pursuit using mini-stations, or handheld devices, for measuring rainfall, moisture, wind direction, temperature, etc.

Air quality and emissions

As for air pollution, generally, all areas in Iraq are highly impacted by air pollutants, mostly emitted by mobile sources, industrial activities, and private generators, while urbanized areas are particularly

https://www.weatheronline.co.uk/Iraq.htm

https://en.wikipedia.org/wiki/Shamal_(wind)

https://www.weatheronline.co.uk/cgi-bin/regframe?3&PRG=cityklima&WMO=40650&INFO=0&PAG=1

http://www.meteoseism.gov.iq/

https://geographic.org/global_weather/iraq/index.html#B


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having the greatest impact. With respect to Particulate Matter (PM), PM2.5 is considered one of the greatest health concerns, in that it can easily access respiratory system, and travel deeper in cardiopulmonary system. The mean annual exposure of PM2.5 in Iraq has been recorded at 73.259 μg/m3 (CEIC, 2016), which is higher compared to the mean annual exposure of 66.25 μg/m3 (2010 – 2016). On the other hand, PM10 annual mean urban was recorded at 208 μg/m3 in Baghdad in year 2015, by 2 residential stations: with heavy traffic, and service region with hospital and heavy traffic (Ambient Air Pollution Database – WHO, 2015).

With regard to Green House Gases (GHGs) emissions from human activities in Iraq, the World Bank’s yearly reports (1970-2012) have shown that the Kt of CO2 Equivalent data was reported at 24,351.17 in Dec 2012. This records an increase from the previous number of 24,112.44 kt for Dec 2011. Worth noting is that Methane emissions, expressed as Kt of CO2 Equivalent data for Iraq is updated on yearly basis, and averaging 21,376.80 kt from Dec 1970 to 2012, with 43 observations. The data reached an all-time high of 32,077.90 kt in 1979 and a record low of 11,188.60 kt in 1991. At the national level, the GOI has reported that the increase percentage of GHG emissions was 1.758% in 2015 compared to 1.621% in 2014.

High rates of air pollutants in Iraq can be attributed to many reasons:

− High numbers of vehicles in general, including old vehicles that still make up a large proportion, as well as the use of fuel that does not meet the environmental specifications for transport and traffic;

− Citizens tend to burn their waste in open air, instead of using municipal collection systems; − Overcutting trees, forests, and palm trees in particular, to cover various needs for fuel, which,

in turn, reduces green areas; − Waste accumulation, and sewage effluents, leading to the release of gases that contribute to

air pollution; − Industries emitting pollutants to the environment; − Air pollution caused by the oil sector: this includes attacking pipelines and fire outbreaks, and

the non-compliant process of flaring petroleum by-products; and − Lacking enough air treatment systems in most power plants.

Noise

Noise pollution generating from human sources include: street traffic, aircraft, railroads, industry, construction, consumer products, and others. On another hand, road traffic is considered one of the most significant sources of noise in Baghdad (Jaleel, 2014). To have a clue about noise problem, measurements, according to Jaleel, were conducted in the vicinity of three hospitals in Baghdad city: Al-Wasity, Al-Elwayia, and Zayed. Results showed that noise level reached 92 dB(A) three meters away from the traffic lane at all hospital locations during daily hours (7:30AM to 2:30PM), which was beyond the permissible limit set by WHO guides.

More information on air quality and noise can be obtained through contacting different Environmental Directorates at the governorate level, and approaching the Ministry of Health and Environment at the central level, and surveys conducted thereof, as well as statistics released by the Central Statistical Organization. Additionally, site-specific interventions should seek ongoing monitoring of noise levels throughout construction periods (for site-specific sub-projects) using handheld devices where construction work is expected to result in rising levels of noise and emissions. This information


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should comprise an integral part of the Environmental and Social Management Plan, where monitoring the physical environment hygiene is critical.

Water resources

Groundwater resources in Iraq account for 0.9 BCM annual. And cover the needs of around 64,000 ha of agricultural lands all around the country. A long time ago, the Iraqi government has drilled thousands of deep wells to cover the needs where surface water is not available. Artesian water has been widely used to supplement irrigation in winter and to irrigate vegetables in summer, in addition to supplying both urban and rural populations with potable water. Other domestic usage includes watering livestock.

Good quality subterranean water could be found in the foothills of the northeastern mountains (only 5 – 50m deep). While water tables could also be found in the semi-flat terrain of central Iraq, at relatively higher levels (300m deep). See the figure below for

Figure 2: Depth of the groundwater in Iraq’s hydrogeological zones (Source: al-Jiburi et. al, 2015)

Currently, groundwater abstraction can be achieved from within the western bank of Euphrates basin, at nearly 13m3/s. Nevertheless, water abstracted there was found of high salinity (more than 1 mg/l) and increasing its salinity until reaching estuaries to the south-east.

Water per capita ranges between 110 to 460 L/ day. However, water treatment services do not currently reach all Iraqis. In 2016, approximately 86% of the urban population and approximately 66% of the rural population have access to an improved water source via the country’s water distribution network. Iraq’s water treatment infrastructure consists of water treatment plants (WTPs), compact units (CUs) and solar plants that are used to treat both surface and groundwater sources. The


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daily production of drinking water is currently approximately 12.5 MCM/day. Baghdad governorate can treat more than 3.5 MCM of water per day whereas most other governorates can treat no more than 1 MCM/day, and many can treat no more than 0.5 MCM/day.

Water tables in Baghdad, for instance, are contained in relatively permeable layers, which would therefore increase possibility of cross-contamination by activities above the ground surface. Quality of groundwater in Baghdad, is in continuous degradation due to intensive usage of fertilizers, seepage of contaminants through soil, intensive discharge of industrial and sanitary wastewaters to land and river, illegal commissioning of cesspits, and others.

Iraq continues to face many problems of poor water quality, resulting from the discharge of sewage from wastewater treatment plants (due to aging, inadequate efficiency and/or capacity) as well as from open channels (Mabazel) to water bodies. In addition to industrial wastewater that are returned to the rivers without enough treatment.

Similar to what was mentioned above, monitoring of water quality around worksites, and downstream would comprise an important part of the ESMP for the site-specific sub-project. Water quality data should be continuously monitored through using monitoring devices, and should be interpreted against baseline information for possibly affected water bodies in the area. Quality information can be retrieved from concerned authorities, for instance water monitoring laboratories at relevant municipalities, in addition to coordination with the Ministry of Water Resources in central Iraqi Government for historical records, and Ministry of Agriculture and Water Resources in Iraqi Kurdistan.

Solid waste

Iraq is estimated to produce 31,000 tons of solid waste every day with per capita waste generation exceeding 1.4 kg per day. Baghdad alone produces more than 1.5 million tons of solid wastes each year (EcoMENA, 2016). Solid waste mismanagement problems remain also of great concern in Iraq, as systems are very old, adding to that collection services are only limited to urban areas within the municipality administrative boundary. Landfills are lacking enough environmental engineering measures, which leads to increasing emissions to the atmosphere and causing further contamination to land and water resources. The National Solid Waste Management Plan was developed in 2007, which sets out many principles for developing the sector, of which responsibilities of waste producers, well-defining the waste hierarchy, and adopting best practicable environmental options are key success factors. Specific information on solid waste management (collection programs, designated landfilling locations, local procedures for disposal of hazardous waste, etc.) in all governorates can be obtained from relevant municipalities, including the Ministry of Municipalities and Public Works of the Central Government. And Ministry of Municipalities and Tourism of the Kurdistan Regional Government (KRG). More statistical and background data on the sector can also be found through the Central Statistical Organization (CSO), and through Kurdistan Region Statistics Office (KRSO).

3.2. Biological Environment Terrestrial Ecosystems

There are several primary and secondary ecoregions belonging to the Palearctic Realm that make up the terrestrial ecosystems of Iraq. The five primary ecoregions that make up the bulk of Iraq include:

− Tigris‐Euphrates alluvial salt marsh;


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− Arabian Desert and East Sahero‐Arabian Xeric Shrublands; − Mesopotamian Shrub Desert; − Middle East Steppe; and − Zagros Mountains Forest Steppe.

In addition, small portions of the following ecoregions can also be found in Iraq:

− Eastern Mediterranean conifer‐sclerophyllous‐broadleaf forest; − Red Sea Nubo‐Sindian Tropical Desert and Semi‐Desert; − South Iran Nubo‐Sindian Desert and Semi‐Desert; and − Gulf Desert and Semi‐Desert

The following Map shows key Ecoregions/ Key Biodiversity Areas (KBAs) and their distribution over Iraqi governorates.

Figure 3: Distribution of Ecoregions in Iraq according to Project areas

(Map modified from: World Wildlife Fund)

Freshwater Ecosystems

The World Wildlife Fund & the Nature Conservancy also defined major freshwater ecoregions and have identified 426 units worldwide. The Lower Tigris and Euphrates River Basins are included because they, and the extensive network of marsh habitats that form at their southernmost end, are among the most important wetland ecosystems of the world associated with these two major rivers. This system also contains a series of large reservoirs, several of which have been designated as Important Birds Areas (IBAs) by BirdLife International including the following lakes:

− Dukan: in Al-Sulaimanyeh, located 55 km northwest of the city of Sulaimani city. − Darbandikhan: in Al-Sulaimanyeh governorate, located 60 km southeast of Sulaimani city


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− Mosul: in Dohuk governorate, located 24 km southwest of Dohuk city − Tharthar: northwest of Baghdad, including administrative border of Salahiddin, and Anbar − Razaza: northern karbala, right on the border with Anbar.

The Tigris River is one of the largest rivers of the Middle East stretching for over 1,900 km, of which 1,415 km are within Iraq. Tributaries include:

− The Greater Zab River, originating in the mountains of the Kurdistan ridge;

− The Rawanduz River, joining the Tigris River 159 km from the outfall, and the Kazir River at 33 km, are the largest tributaries. The total river length is 473 km. The two rivers join the Greater Zab first and Tigris River later at 1,161 km from the outfall;

− The Lesser Zab River originates in Iran in the Zagros Ridge. Within the territory of Iraq, the river runs along the Rania Valley. The total river length is 456 km. The Lesser Zab joins the Tigris River 1,046 km from its outfall;

− The Adhaim River originates at the confluence of the Taukchai, Arou, and Kazachai Rivers. The river runs only within Iraq. The river length is 230 km; and

− The Diyala River originates on the southeast spurs of the Zagros Ridge. Within Iraq it receives considerably large tributaries: the Tanjero and Limkana; the Abbasan and Aiwend Rivers downstream; and the Dewana River from the right side.

The earthen Mosul Dam was completed in the early 1980s on the Tigris River upstream of the city of Mosul in the governorate of Ninawa. It is the largest dam in Iraq, with a total capacity of 11 billion cubic meters of water.

The Euphrates River originates in the mountains of Turkey on the Armenian plateau. It is formed by the confluence of two rivers: the Karasy River and the Murad River. The total length of the Euphrates River from the source of the Murad River to its confluence with the Tigris River is 2,940 km, of which 1,159 km runs within Iraq. The lakes in central Iraq (e.g. Tharthar Lake) were saline depressions that were converted to store water for flood control and now support a fish fauna.

Biodiversity

Biodiversity in Iraq can be discussed at many levels. However, three specific types of species relate to the global importance of Iraqi biodiversity could be highlighted for the sake of this Framework. These include:

− Migratory species – species for which Iraq is important during one point of their life cycle when they migrate through Iraq;

− Endemic or semi‐endemic species – species that are unique to Iraq or regional ecosystems found in Iraq; and

− Species endangered, threatened, or vulnerable to extinction.

Fauna

The International Union for the Conservation of Nature (IUCN) Red List of Endangered Species provides conservation status on many species (both migratory and endemic) that are facing declines and potentially extinction through its on‐line Red List (www.iucnredlist.org). A preliminary checklist of the Birds of Iraq includes 417 bird species of which 182 are considered passage migrants to Iraq


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and an additional 27 are vagrant species. Of these, 18 species are considered to be of conservation concern, the majority of which are either possible or confirmed breeders. Five species of birds in Iraq are either endemic or have endemic races.

Many marine fish utilize the Iraqi marshlands for spawning and nursing grounds making this ecosystem particularly important to regional biodiversity. Some 106 species of fish (including freshwater and marine entrant species) have now been recorded in the non‐marine waters of Iraq and of these 53 species are marine fish. According to the Freshwater Ecoregions of the World website (www.feow.org/index.php), three of these fish are endemic in the Tigris/Euphrates Basins ecoregion: Glyptothorax steindachneri; Caecocypris basim, and Iraq blind barb (Typhlogarra widdowsoni). The last two are listed as Vulnerable on the IUCN Red List.

Little information exists on other globally important fauna species of insects, amphibians, reptiles, and mammals. A list of ten amphibians, ninety‐seven reptiles and seventy‐four mammals has been compiled from the literature. Many species are of conservation concern and several of these may be endemic or near‐endemics such as the vulnerable Mountain newt (Neurergus crocatus), the endangered Kurdistan Newt (Neurergus microspilotus) and the endangered Euphrates Softshell Turtle (Rafetus euphraticus). Twenty species of mammals are of conservation concern and Iraq has two endemic/semi‐endemic species: the Mesopotamian gerbil (Gerbillus mesopotamiae) and Cheesman’s gerbil (Gerbillus cheesmani).

Flora

As for flora, the major ecoregions mentioned above are characterized by certain vegetation. The Tigris‐Euphrates ecoregion’s vegetation is dominated by aquatic plants such as reeds (Phragmites sp) and rushes (Typha sp). Unfortunately, the vegetation of the Arabian Desert and East Sahero‐Arabian Xeric Shrublands has received almost no study in recent years during the spring annuals growth and flowering after winter rains. Several uniquely adapted plants are likely to exist in this region. The same situation applies to Mesopotamian Shrub Desert ecoregion.

However, Vegetation of the Middle East Steppe ecoregion reflects the Mesopotamian province of the Irano‐Turanian region. Herbaceous and dwarf shrub sage brush (Artemisia sp) communities tend to dominate in deeper, non-saline soils and often occur in association with grasses. These are important grassland habitats and during summer many Bedouin can be seen bringing their herds northward to take advantage of the spring and summer grazing. This ecoregion also contains areas of barren, hard, rocky soils called Hammada. Areas along the Euphrates and Tigris Rivers provide riparian vegetation and habitats with mixes of Tamarix, Salix and Populus species as well as Typha sp and Phragmites sp.

3.3. Socio-economic Characteristics It is estimated that Iraq is inhabited by nearly 39 million people in 2018. While census held in 2014 showed that population of Iraq was 36,004,552 (CSO, 2014), with a population growth rate of 2.5%. The following table shows population distribution for all Iraqi governorates, including sub-distribution according to gender.

http://www.feow.org/index.php


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Table 2: Population distribution in Iraqi governorates – 2014 Governorate Muthanna Salahiddin Dohuk Ninawa Baghdad Dhi-qar Qadisiyah Kirkuk Diyala

Male 403,177

(52.3%)

773,013

(51.2%)

745,040

(61.0%)

1,637,016

(46.4%)

3,885,765

(50.7%)

1,029,113

(52.0%)

642,706

(52.7%)

769,359

(51.0%)

797,163

(51.5%)

Female 367,299

(47.7%)

736,140

(48.8%)

475,356

(39.0%)

1,887,332

(53.6%)

3,779,527

(49.3%)

950,449

(48.0%)

577,627

(47.3%)

739,495

(49.0%)

751,329

(48.5%)

Total 770,476

(2.1%)

1,509,153

(4.2%)

1,220,396

(3.4%)

3,524,348

(9.8%)

7,665,292

(21.3%)

1,979,561

(5.5%)

1,220,333

(3.4%)

1,508,854

(4.2%)

1,548,492

(4.3%)

Governorate Mesan Najaf Wasit Anbar Babel Karbala Basrah Erbil Suleimaniyah

Male 522,414

(49.7%)

704,069

(50.7%)

659,511

(50.6%)

865,846

(51.7%)

980,422

(50.2%)

600,324

(52.1%)

1,375,384

(50.1%)

891,002

(50.9%)

1,037,686

(50.9%)

Female 528,166

(50.3%)

685,480

(49.3%)

643,626

(49.4%)

809,760

(48.3%)

972,762

(49.8%)

550,828

(47.9%)

1,369,375

(49.9%)

858,913

(49.1%)

1,002,082

(49.1%)

Total 1,050,580

(2.9%)

1,389,549

(3.9%)

1,303,137

(3.6%)

1,675,606

(4.7%)

1,953,184

(5.4%)

1,151,152

(3.2%)

2,744,758

(7.6%)

1,749,915

(4.8%)

2,039,767

(5.7%)

Source: CSO 2014

The following Table and Chart show distribution of age categories according to gender.

Table 3: Age distribution in Iraq – 2014

Age category Male Female Total

0-9 4,971,762 4,724,068 9,695,830

10-19 4,304,873 3,988,286 8,293,159

20-29 3,254,075 3,036,401 6,290,476

30-39 2,244,044 2,242,092 4,486,136

40-49 1,751,556 1,727,346 3,478,902

50-59 917,030 1,012,239 1,929,269

60+ 875,668 955,112 1,830,780

Grand Totals 18,319,008 17,685,544 36,004,552

Figure 4: Age distribution in Iraq – 2014

0

2,000,000

4,000,000

6,000,000

8,000,000

10,000,000

12,000,000

0-9 10-19 20-29 30-39 40-49 50-59 60+

Male Female Total


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In the context of recent conflicts, Iraq witnessed unprecedented waves of eviction and displacement as a result of the terrorist operations and the accompanying repercussions. Although the entire Iraqi society has been affected by the war on terror, women and girls, particularly those subjected to abuse, remain the primary target of the attacks, which included gross violations of human rights. Kidnappings, killings, human trafficking, forced marriage and sexual violence are of concern and call for intervention and support to alleviate the suffering, reintegration and rehabilitation of people who have experienced the horrors of this experience. About 1.9 million women have been displaced and in areas of conflict and war, they made up 51% of the total displaced people as a result of the recent waves of displacement and are still so far suffered the harsh conditions. Therefore, Iraq is expected to face many challenges that would inhibit the creation of a positive relationship between development and population.

According to the sustainable development plans (2018-2022), Iraqis within the labor force category are almost 9 million out of 35.2 million people in 2015, forming approx. 25.9%, of which only 14% are female workers, and 86% are male workers. This is well below the already low rates of female labor force participation in the Middle East and North Africa (MENA) Region of 22% – compared to about 72% of adult men. This reflects a significant gender-based gap in the labor force.

Among youth (ages 15 – 29), 72% of women and 18% of men are neither in school nor employed. The same report mentioned above indicates that unemployment had risen to 10.8% in 2016, compared to 10.6% in the preceding year. However, in 2014 unemployment among men was 8.4%, while among women, it was 21.9%. It is also worth mentioning that unemployment rate was peaking in the age group 15-19 which amounted to 24.5%, while lowest rate was found 2.9% among age group 60-64. In Anbar, unemployment rate was one of the highest 19.6%, while in Kirkuk, it had the lowest rate 2.9%.

There is a large variation in the rates of underemployment in Iraq at the provincial level. This can be explained by the different nature of work and economic activities prevailing in each province as well as the decline in the overall economic performance at the national level.

The GOI has adopted many policies and programs that would provide employment opportunities for vulnerable groups. There were four programs targeting vulnerable and marginalized groups in society and aiming to provide decent work for the unemployed and all affected groups. The first was the Community Rehabilitation Program in cooperation with the International Labor Organization (ILO) for the period 1997-2004, during which 868 projects were completed. However, the project stopped then, and returned to operate as a national project from 2007 until 2016, during which 383 projects were implemented. The second program was the microfinance program for the period 2007-2009, during which 73,323 projects awarded worth US$ 328 million in total. And the third one was of the National Strategy for Poverty Alleviation since 2012 in cooperation with the Ministry of Planning, continued until the end of 2016, and focused on the poorest provinces, the program granted during this period 10,896 loans worth 86 billion Iraqi dinars. While the fourth program was the support fund for small income-generating projects, which targeted all governorates according to the population weight (excluding the Kurdistan region) and granted during the period 2013-2016 to 49,907 loans worth more than 212 billion Iraqi dinars.

In general, the GOI lacks accurate indicators about the labor force in the private sector. There is no specific data on the informal sector as a whole. In tracking the development of the number of private sector employees, their ratio to the total number of workers in the economically active category declined to 59% in 2012, and this percentage continued to decline to 58% in 2014. This was an


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undesirable change in the results of the economic crisis, which had a significant impact on the economy of the country on one hand, as well as the increase in the number of entrants to the labor market and thus increased the number of unemployed on the other hand. This, in turn, has led to an increase in the proportion of workers in the government sector at the expense of the private sector. The agricultural sector is the largest source of rural employment and livelihood in Iraq, with critical implications for climate resiliency, food security, poverty alleviation, and the empowerment of women, but is drastically underexploited.

The average per capita monthly income of Iraq at the market price was 330.3 thousand IQD, according to the semi-annual social and economic survey for 2014, thus, achieving progress on the latest survey for the year 2012 that indicated 237.4 thousand IQD. While the index of average per capita monthly expenditure amounted to 597.1 thousand IQD. However, at the household level, average income was 1,875.4 thousand IQD, and average expenditure was 1,960.7 thousand IQD. The following table summarizes income and expenditure rates for all Iraqi governorates.

Table 4: Distribution of income and expenditure at per capita and household levels Governorate Gross income (market price,

thousand IQD) Gross expenditure (market price, thousand IQD)

Per-capita Household Per-capita Household

Dohuk 402.1 2,405.1 435.7 3,6067.7

Ninawa 218.8 1,578.1 192.4 1,467.0

Suleimaniyah 408.8 1,848.5 471.7 2,378.1

Kirkuk 372.7 1,985.1 259.3 1,601.5

Erbil 599.2 2,753.8 597.1 3,271.0

Diyala 265.8 1,301.0 199.6 1,144.4

Anbar 224.9 1,511.2 218.5 1,586.7

Baghdad 426.8 2,165.4 410.7 2,459.7

Babel 266.2 1,549.7 221.7 1,542.2

Karbala 30.9.0 1,839.5 276.7 1,851.9

Wasit 285.6 1,852.5 242.0 1,821.4

Salahiddin 269.5 1,644.4 268.0 1,852.9

Najaf 287.9 1,946.3 233.4 1,696.9

Qadisiyah 227.0 1,399.9 185.6 1,354.6

Muthanna 205.5 1,466.8 162.8 1,364.2

Dhi-qar 282.9 1,703.9 190.9 1,329.4

Mesan 285.7 1,930.6 246.4 2030.0

Basrah 251.4 1,770.4 201.6 1,532.4

Source: Iraq Sustainable Development Plan (2018-2022)

Poverty in Iraq was as low as 22.5% in 2014. However, in areas controlled by ISIS, poverty increased from 19% by end of 2013 to 41% in 2014. As for, child labor, the proportion of children who were engaged in work between the ages of 6-14 years, reached 3.5% of the number of children within this age group. However, it is believed that there is 5.4% under child labor. And there are one million orphaned children forced to work by their bad conditions. Reports in this regard, say that 70% of


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displaced children missed a full school year. The number of displaced children is 1.6 million, which comprises 50% of the total number of displaced persons (3.2 million in 2014).

Social and educational statistics for the academic year 2016/2017 indicate the net enrollment rates in primary education (6-11 years) in public, civil and endowment schools was highest in the governorates of Muthanna 97.5, Dhi-Qar 97.1, Baghdad 97, Basra 96.5, Karbala 96 and Najaf 95.1. While the lowest enrollment rate was recorded at 72 in Anbar, for the same year. Moreover, statistical surveys show that the dropout rate for the intermediate level increased from 2.2% for the school year 2012-2013 to 8.1% for the year 2015 - 2016 for females, while it increased from 3.7% to 4.9% for the same years for males. However, dropout rate at the preparatory level increased from 1.5% during the school year 2012-2013 to 1.9% for year 2015 - 2016 for males, while it decreased from 2.6% during school year 2012-2013 to 1.9% during year 2015-2016 for females. As for enrollment rate of age group 15-17 (i.e. preparatory level) it increased from 24% in the year 2012-2013 to 29% for the year 2015-2016.

As for infrastructure at public schools, the number of buildings under construction (implemented by the ministries of education and governorates according to the plan of development) reached 2,339 buildings with different completion rates. The majority of these buildings were closed due to the financial crisis experienced by the country. The number of buildings damaged by terrorist operations was 1,380, of which 674 completely damaged, and 706 partially damaged.

According to the Iraqi Food Security and Vulnerability survey conducted in 2016, woman-headed households at the national level was 10.5%, noting that the highest proportion was registered in Baghdad 13.6%, followed by Suleimaniyah 12.3%. Terrorist operations, eviction, and displacement have affected women in particular. This has resulted in a big number of women either widowed or divorced in their dependent households. According to Women’s Freedom Organization in Iraq, the number of women in 2015, who were abducted, raped, sold/bought, and suffered the psychosocial damage therefrom, was 4,000, as a result of the recent crisis.

Additionally, according to a 2007 World Health Organization (WHO) study – the last reliable healthcare survey conducted in the country – mental health disorders were the fourth leading cause of ill health in Iraqis over the age of five years. One year earlier, Médecins Sans Frontières (MSF) estimated that as much as one-third of all children in Baghdad, Mosul, and Dohuk demonstrated symptoms of moderate-to-severe mental illnesses. In Mosul, which reported the highest percentage of post-traumatic stress-related cases, less than 10% of children in need of care had received any level of treatment. In a separate study, nearly 35% of 9,000 self-reporting households suffered “significant psychological distress.” By the end of 2007, the Iraqi Ministry of Health reported that over 70% of those with any mental health condition had experienced suicidal thoughts.

Data provided above intended to shed the light on key socio-economic indicators in Iraq, for the sake of this ESMF. However, site-specific ESMPs need to acquire all relevant, up-to-date socio-economic information for the locality hosting the sub-project activities, especially within the work packages of Component 1. The contractor/ implementing agency should pursue information from official agencies, like directorates of MOP, MOH&Env, MOLSA. CSO, and others. In case of missing data, these should be complemented by engaging socio-economic specialists for preparing this part of the ESMP, who in turn, could undertake various interpolation and projection methods, and provide subject matter judgment, in addition to consulting community leaders and researchers.

https://www.msf.org/sites/msf.org/files/english_iraq_mental_health_final_report.pdf

http://www.who.int/mediacentre/news/releases/2008/pr02/2008_iraq_family_health_survey_report.pdf


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Chapter 4: Policy, Legal, and Regulatory Framework

This Chapter provides an overview of applicable Iraqi and World Bank’s policies, laws, and regulations pertinent to addressing all environmental and socio-economic aspects of the Project. It would also provide a good framework reference for assessing and managing social and environmental impacts brought about throughout the Project’s life cycle, inclusive of smaller sub-projects of Component 1. The activities of this proposed development are expected to comply with provisions and requirements of this legal register during screening and implementation stages. Monitoring of pollutants levels is also mandatory against Iraqi standards and instructions. However, the borrower (MOP) is expected to adhere to most stringent safeguards in managing impacts, for instance, those related to Occupational and Community Health and Safety.

4.1. National Laws and Regulations Constitution of Iraq

Equal opportunities are guaranteed for all Iraqis. The state guarantees the taking of the necessary measures to achieve such equal opportunities. Work is a right for all Iraqis so as to guarantee them a decent living. The law regulates the relationship between employees and employers on economic basis and with regard to the foundations of social justice. Economic exploitation of children shall be completely prohibited. The State shall take the necessary measures to protect them. The state guarantees to the individual and the family -- especially children and women -- social and health security and the basic requirements for leading a free and dignified life. The state also ensures the above a suitable income and appropriate housing. The State guarantees the social and health security to Iraqis in cases of old age, sickness, employment disability, homelessness, orphanage or unemployment, and shall work to protect them from ignorance, fear and poverty. The State shall provide them housing and special programs of care and rehabilitation. Every citizen has the right to health care. The state takes care of public health and provide the means of prevention and treatment by building different types of hospitals and medical institutions. All forms of psychological and physical torture and inhumane treatment shall be prohibited. Compulsory service (unpaid labor), serfdom, slave trade (slavery), trafficking of women and children, and the sex trade are prohibited as well.

Every individual has the right to live in a safe environment. The State undertakes the protection and preservation of the environment and biological diversity.

According to the Constitution, federal authorities and regional authorities, shall be responsible for formulating the environmental policy, to ensure the protection of the environment from pollution, and to preserve its cleanness in cooperation with the regions and governorates that are not organized in a region.

The Ministry of Planning, Law no. 19 – year 2009

According to the Law, the Ministry of Planning has been established. The overarching objectives are:

To achieve economic and social development and optimize the use of energy, and human and asset capital, as well as to develop development processes in order to improve performance and efficiency of the government system. Key responsibilities of the MOP include: conducting studies and preparing plans for economic and human development in Iraq; preparing annual strategies for various development aspects (poverty reduction, social protection, employment, etc.); providing indicators


33

and statistical data for other state entities; overseeing and reporting on technical and financial assistance of the international cooperation agreements; promoting partnership and assessing development needs of the private sector; as well as issuing relevant regulations and standards. The MOP through its Directorate General of Poverty Reduction Strategy will be held responsible for the SFD Project Management for the first three years of the project lifetime.

The National Development Plan, 2018 – 2022

The newest National Development Plan (NDP) for the year 2018 – 2022 addresses, amongst others, a range of social and environmental challenges, and puts forward strategic objectives and instruments for implementation. According to NDP (2018 – 2022), social challenges included, weak ranking of Iraq among the middle-developed countries; weakness of the rule of law and access to justice; raise of multi-dimensional poverty levels caused by successive crises, conflicts, and population displacement and instability; increasing fragility and rate of vulnerability; gender gap and failure to include youth; and continued decline of education and health services indicators.

The NDP highlighted many environmental challenges. These included, amongst others, lack of urban planning; non-integration of environmental management; lack of environmental legislation; desertification; climate change; and exploitation of non-renewable energy resources.

Economic Empowerment through Income Generating Projects, Law 10 – 2012

The provisions of this Law are compatible with the Iraqi national plans for social and economic development. The Law aims at reducing unemployment and eradicating poverty through providing small investment opportunities and enabling environment thereof; providing financial and technical assistance to individuals under concern; facilitating and guiding throughout projects’ registration and approvals; and increasing productivity and supporting economy at the national level.

By virtue of this Law a financing fund is established within MOLSA, which is headed by Minister of MOLSA and steered by a Management Board that includes members from other six ministries; Ministry of Finance (MOF), Ministry of Planning (MOP), Ministry of Industry and Minerals (MoIM), Ministry of Transport (MOT), and Ministry of Agriculture (MOA). The Management Board is responsible for setting up lending and reimbursing policies and procedures; planning, coordinating, promoting, and approving microfinances; in addition to providing technical support whenever needed. According to the Law, the ceiling limit of a loan is IQD 20 million, and investment opportunities are advertised at the national level and coordinated with civil work organizations and private sectors.

Social Protection Law no. 11 – 2014

The new Social Protection Law No.11 of 2014 has emerged from reforming the old Social Welfare Act no. 126 of 1980, which had been effective for 35 years. The new Law is influenced by successful social protection systems in developed countries, and aims to avoid the errors of previous social protection experiences in Iraq. It targets Iraqi families and individuals as well as foreign nationals residing in Iraq, who live below the poverty line.

Under Article 6 of this Law, the Social Protection Council was established, which is associated with Ministry of Labor and Social Affairs (MOLSA) with enough authority to alter the organizational structure of the Social Protection Network and taking over its function. The Article also ties the amount of aid provided through the Social Protection Council to the poverty line. It also discusses targeting mechanisms and terms for receiving aid as shown in table below.


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Table 5: Amount of social assistance according to family size – Law 11 of 2014

Family size 1 2 3 4+

Amount of social assistance (in thousand IQD) 105 210 315 420

Articles 18 and 19 are concerned with the establishment of the Social Protection Fund, which is managed by a board of directors, headed by the head of the social protection authority, the heads of the authority’s departments, and additional members from the relevant ministries (finance, education, health, planning, justice and interior). Lastly, the law is inclined towards a more decentralized form of management relative to the previous arrangements. However, there are some shortcomings, one of which is related to the new services and increasing subsidies, which requires more accurate targeting of the beneficiaries. Another shortcoming is that source of funding was not specified. In addition to, giving the right to invest the Fund’s money, which is not commonly tied to this type of fund.

Labor Law no. 37 – 2015

Law No.37/2015, including Instruction No.12 of 2016 for Occupational Health and Safety, differentiates between jobs depending on the circumstances and duties that the employees are conducting. The Law organizes the relationship between the employer and employees, with the aim of protecting their rights and realizing sustainable improvement based on social justice, equality and providing suitable work for everybody without discrimination. The Law prohibits all types of compulsory labor and child labor and determines minimum working age (15 years) and to prevent any discrimination or harassment, whether direct or indirect.

Article 63 of Chapter 7, gives the MOLSA’s minster the authority to formulate a committee of 8 members to determine minimum levels of national wages. However, decision is made in light of several factors, including needs of workers and families, level of wages, cost of living, and economic factors (development, market, productivity, employment, etc.).

The Law regulates the work of female employees by granting additional rights. Furthermore, it regulates the work of subcontractors regarding the employees’ rights. The Law also regulates health of employees and stipulates that the National Centre for Occupational Health and Safety is to be in charge of planning and inspecting the implementation of health affairs to guarantee the safety of employees at worksites from occupational diseases and injuries, in addition to requirements for healthy work environment. Workers must follow orders and instructions regarding measures of protection and occupational safety and must carefully use the protective devices entrusted to them.

Acquisition Law no. 12 – 1981

This Law is applicable to all properties of agricultural, non-agricultural lands and orchards. Disposal rights of government-owned land. And other original specified rights relevant to property.

It is the only Iraqi law that governs the rules of expropriation of property for the purposes of public benefit. According to the Law, acquisition includes: expropriation of property through acquisition, or is, by virtue of the acquisition, similar to taking over the compensations and replacement costs, cancelling the legal right and other applications of expropriation, for the public benefit. The law has adopted rules and foundations common to fair compensation for all property acquisition and guarantees the rights of possessor without prejudice to public interest. The Law stresses the


35

importance of fair compensation especially for agricultural lands. The Law highlights procedures for negotiating expropriation with the property owner, and addresses administrative acquisition cases.

The Law, so far, has no reference to compensation for lost assets, income, means of livelihood, or displacement from land of no legal right.

4.2. National Environmental Legislations Public Health Law no. 89 – 1981

The Public Health Law is considered the backbone for protecting public health from harmful interaction with the environment and vice versa. In so doing, the Law tackles issues related to the environment that has direct and indirect impact on human health and wellbeing. The Law has dealt with a number of environmental aspects like, preserving natural coherence, water, land, and air. The Law has outlined the healthy burial of waste by determining fundamentals of this act, like site selection, methods of burial, machinery required, and staff involved, amongst many others. In opting for burial, cultivable lands and high groundwater tables should be avoided whenever possible, sought outside of urban/suburban areas, and operated in such a way to prevent odor and pest breeding.

The Law has also included the safe handling and storage of chemicals. The need for suitable signage, minimizing quantities and the need to store hazardous materials, and replacing them with less hazardous ones if possible.

The Law stressed on protection of workers from sources of noise and vibration. By virtue of this Law, the employer is required to use low-vibration equipment, monitor levels of vibration in workplace, provide their workers with proper protection equipment, as well as offer their workers proper medical checks and treatment for those directly exposed. The Law, in its Article 99, has set out penalties for breaching cases in comparison to limits detailed in relevant regulations.

Public Health Law / Safe storage and handling of chemicals, instructions no. 4 – 1989

These Instructions set out requirements for safe handling and storage of chemicals according to the provisions of Articles 3 & 105 of the Public Health Law. They apply to activities involving the use and handling of: explosives; flammables; oxidizing substances; corrosive, radioactive, and carcinogenic chemicals; chemical drugs; toxic chemicals and pesticides; chemical irritants; and inert chemicals. Article 2 outlines necessary precautions for handling and storing chemicals and the need for proper signage. Placement of hazardous with less hazardous materials is required if possible, along with storing hazardous materials at the minimum possible quantities. Article 3 outlines the suitable signage and labeling, security and safety, as well as adopting an international classification system by the manufacturer. Articles 4 and 6 outline requirements for storing chemicals, such as, properties of chemicals to be stored, protecting chemicals from damage, exposure, or fire, as well as transporting chemicals containers to and from storage places. The instructions also set out details for safe storage and use of the chemicals, disposal of waste chemical containers, and the actions to be taken on the event of the release of a chemical. In addition to the need to use Personal Protective Equipment (PPE) by individuals working with such chemicals.

Protection and Improvement of the Environment Law no. 27 – 2009

The Law aims at protecting and improving the environment through elimination and treatment of existing damages or those likely to be caused. It also aims at preserving public health, natural resources, and biodiversity as well as natural and cultural heritage in coordination with the relevant


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authorities in a manner that ensures sustainable development through international and regional cooperation. Article 3 of this Law establishes the "Environment Protection and Improvement Council", which is associated with the Ministry of Health and Environment and includes 22 representative members from all ministries and commissions. Roles and responsibilities of the Council include (amongst others): providing advice on environmental issues; reviewing plans, projects, programs, including emergency and environmental disaster plans, all in relation to environmental aspects before approval; internally coordinating between authorities and externally presenting the country in the environmental regional and international forums; implementing environment improvement project in Iraqi provinces; and taking part in formulating environmental legislations as well as preparing annual reports on the environmental situation. Article 7 of the Law entails the establishment of Environment Protection and Improvement Councils in each governorate. Articles 11 and 12 relate to new and expansion projects respectively, and the need to prevent or encourage developments in line with protecting natural resources, adopting sustainable and environmentally-sound systems, and exploring renewable energy sources.

Article 14 (protection of water resources from pollution) prohibits: Discharge of domestic, industrial, and agricultural effluents to inland water resources without proper treatment, in compliance with specifications set out in environmental-related legislations; Disposal of solid waste, animal waste and corpses, or scrap material into water resources; Discharge of waste oil, wastewater, or fuel from tankers to surface water or territorial waters; Any act that would lead to pollution of surface water bodies as a result of exploitation of the river, unless otherwise approved.

Article 15 (Air pollution and noise reduction) prohibits: Emissions of fumes, gases, or vapors in excess from production processes, or burning fuel, and considers that a breach of national environmental legislations; Excessive emissions from engines and vehicles above permissible limits; Burning of solid waste outside of designated areas, given that this is done in an environmentally friendly manner.

Article 16 prohibits high levels of noise that exceed permissible limits, in the operation of machinery, equipment, horns, and loudspeakers.

Article 17 (Protection of land) which prohibits: Activities that would lead to degradation or pollution of soil either directly or indirectly; Non-compliant urban sprawl on land; Activities that would result in desertification or impacting natural environment, unless otherwise approved; Damage to designated areas of natural and cultural heritage, including unauthorized disposal of solid waste in such places.

Article 18 (Protection of biodiversity) which prohibits: Damaging biota in their habitat; Fishing, hunting, killing, and transferring endangered/ protected species; Damaging plants/ herbs of medical, scientific, industrial, and trade values; Cutting perennial trees in public areas, logging in the forest, and introducing new animals and plants in the environment all unless otherwise permitted.

Articles 20 addresses the need to: control the use of pesticides and chemical compounds; Apply an environmentally-sound method for transferring, handling, storing, and disposing hazardous materials including radioactive ones; ensure those materials not causing harm/ damage to the environment; prohibit treatment of hazardous waste without prior permit. And Article 22 is related to the environmental monitoring for prohibited activities that impact the environment.


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Environmental Protection and Improvement in Kurdistan Region, Law no. 8 – 2008

The overarching goals of the Law include: maintaining, improving, and protecting environment from pollution; protecting nature and public health from dangerous/ harmful activities to human and environment; maintaining and developing natural resources; mainstreaming environmental policies within development planning; and raising level of environmental awareness. The Environmental Protection and Improvement Council in the Region has been established according to the Law.

Responsibilities of the Council include: formulating general policies, specifications, and standards for environmental protection and components, confirming environmental management measures in projects and activities; as well as the evaluating the environmental impact and environmental consents (i.e. the preparation and approval of Environmental Impact Assessments). The Council puts lists of projects requiring different level of detail of EIA and procedures for obtaining permits from the Ministry of Environment. The Law also prohibits discharging of harmful substances into water resources/streams, and prohibits emissions to air, as well as prohibits contamination of land and soil. The Law also calls for protecting biodiversity and coordinating all related efforts with the central Iraqi Ministry of Environment.

Protection of Wild Animals and Birds, Law no. 21 – 1997

As detailed in Article 2 of the Law, implementation and monitoring shall be entrusted to the "Special Administration", whereas Article 3 is concerned with the breeding of wild animals in protected areas and creation of natural habitats for wild animals and birds. The Law requires the Minister of Agriculture and Land Reclamation to issue a list of protected species of birds and animals, prohibited zones, and hunting seasons. Hunting may only be authorized by the Minister of Agriculture and Land Reclamation, which if not granted will result in a fine or an imprisonment or both.

Forest Law no. 30 – 2009

According to this Law, forests are classified into three categories: State forests, Endowed forests, and Private forests. The provisions of the Law are applicable to State forests, though; Article 4 still contains general provisions for all forests. In particular, the Law is assigning administration of protected/reserved forests to the Directorate General of Forests and Plantation. The Law also deals with enforcement and sets out offences and penalties. Furthermore, the Law prohibits cutting forest trees for charcoal and commercial purposes in specified natural forests according to Article 1. However, villagers are allowed – for particular purposes – to cut trees for timber and to transport it within the forest region (Articles 3 & 4).

Decision Concerning the Cutting of Trees no. 1 – 1991

By virtue of this Decision, it is prohibited to cut trees from natural forests and street sides, as well as from areas with young trees and green belts. Failing to comply with the Order will result in punishment according to the provisions of the "Protection and Improvement of the Environment Law no. 27 – 2009."

Preservation of Water Resources Regulation no. 2 – 2001

As mentioned in article 8 of this regulation, it is prohibited to discharge or throw any kind or any amount of waste to the common water of any kind or quantity, whether the discharge is regular,


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irregular or temporary, unless granted permission from the Office of Protection and Improvement of the Environment or whom it shall authorize.

Protection of Ambient Air Quality Regulation no. 4 – 2012

This Regulation was derived from the Protection and Improvement of Environment Law no. 27 described above. According to the Regulation, the Ministry of Health and Environment is responsible for: establishing a monitoring program on the national scale, including the provision of monitoring equipment and pursuing fund opportunities; using data collected from monitoring stations and utilizing them in preparing environmental reports; putting a national guide for air-polluting substances; issuing allowable limits of air pollutants; managing and controlling air pollution from stationary and mobile sources in collaboration with relevant authorities.

The Regulation requires that stationary emitting sources adhere to national thresholds and use monitoring devices to ensure compliance. It is also required that emissions from electricity generators using a hydrocarbon fuel are kept within limits, applying corrective measures in case of exceeding limits, and seeking alternative/new technologies to replace the old ones.

According to the Regulation, it is prohibited to burn all types of plastics, rubber, used oils, materials containing heavy metals, medical wastes, domestic wastes, inside a facility, or in the open air, or next to a residential area or a water source. Dumping facilities and incinerators are to be established in full compliance with national and international standards.

According to the Iraqi National Clean Air Act issued in 1979, the Air Quality Standards set out the limits based on a medium-termed policy targets that take into consideration economic efficiency, practicability, technical feasibility, and timescales, which mostly agree with the WHO guideline limits. See Annex I-a for ambient air quality standards set by the local regulator with those internationally indorsed by the World Health Organization (WHO). These limits are applicable to emissions from stationary sources by different activities rather than being industry-specific.

The new determinants for the Prevention of Pollution of Rivers and Public Water Regulation, no. 25 – 1967

This instruction sets the new determinants for the prevention of pollution of rivers by virtue of Regulation 25, 1967. These instructions set physical, chemical, and biological guidelines for water quality and wastewater discharges. The Regulation defines Water Resources as: rivers, streams, waterways, lakes, springs, wells, and groundwater. In particular, these instructions apply to wastewater discharge from cities, industry, agriculture, and other activities to: public water sources, public sewers, and marshes. Annex I-b, presents limits defined for discharges to both natural waters (water resources) and sewers (which generally have higher permissible discharge limits).

Antiquities and Heritage Law no. 55 – 2002

It is considered a violation of the Law discovering, taking, purchasing or receiving as a gift any antiquity or heritage material that originated in Iraq, without promptly notifying and registering the object with the State Board of Antiquities and Heritage. No one is allowed, by means of excavating, digging, or discovering, to take antiquity material without a written permit. The same is applied to removing or transporting any antiquity or heritage material from Iraq to abroad.


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Violating the provisions of the Law could lead to imprisonment (up to 10 years) and a fine of 100,000 IQD. However, illegal excavation would lead to imprisonment (up to 15 years) and a fine of two times the value of the damages sustained. Trafficking in antiquities, on the other hand, is punishable with imprisoning for a period not exceeding 10 years and a fine of up to 1,000,000 IQD.

Environmental Assessment – Establishing the Ministry of Environment Law No. 37 – 2008

Provides a definition to environmental impact assessment. Projects under this requirement are those expected to have effects on human health and environment integrity as a result of going through the project cycle. The Ministry of Environment (MoEnv) – which has been recently attached to the Ministry of Health – is responsible for preparing regulations and issuing instructions for environmental measures and monitoring their best implementation. Also, MoEnv has the authority to approve locations for new developments in terms of their environmental context and give advice in coordination with other responsible ministries and entities. The Law also empowers the local councils for protection and improvement of the environment to perform field inspections and monitor actual implementation of Environmental Management Plans (EMPs) on the ground, as well as apply a fine system should provisions of the Law be breached.

EIA categorization – Environmental Criteria for Carrying out Projects and Monitoring Appropriateness of Implementation Instructions no. 3 – 2011

These instructions were issued by the MoEnv to set criteria for classifying projects in Iraq into 3 main categories: A, B, and C, which will be used later on to either approve or reject the proposed project location in light of identified impacts. The criteria were based on level of significance of adverse impacts and magnitude of impacts/ boundaries of influence. Accordingly, projects should be categorized under one of the following for an environmental assessment:

− Category A: Projects within this level are expected to have high significant impacts on the vulnerable biological environment, locations of cultural values, or impacts having a much broader area compared to where the project is taking place. Under this category, a resettlement could be triggered as a result of implementing the project. For each type of projects listed under Category A, a set of recommendations/ mitigation measures is proposed;

− Category B: Projects within this level are expected to have less significant impacts compared to those of Category A, but these impacts would be considered irreversible on the biological environment. Impacts of Projects under this category are described as being site-specific; a range of mitigation measures could be applied to alleviate negative impacts. A preliminary EIA is to be prepared.

− Category C: Projects within this level are expected to have no or minimal adverse impacts on the environment; any resulting impacts could be fully controlled/ minimized. No EIA is required in this case.

The Project proponent is also required to apply for an environmental compliance certificate from the MOH&Env by initially undergoing an environmental screening/assessment to account for the expected impacts. If not clearly listed in any of the three categories' projects, the project will be screened by the MOH&Env given the submission of necessary documentation by the project proponent.


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4.3. Roles and Responsibilities in the Field The following Table provides an overview to the roles and responsibilities of concerned parties/ authorities in the field (applicable to all governorates under the Project, excluding KRG), which can be linked to the different SFDP’s interventions (component 1 in particular).

Table 6: Roles and responsibilities in the field (including KRG)

Department Key roles and responsibilities 1. Iraqi Ministry of Health and Environment 2. Board for the Protection of the Environment at KRG

- Determination of level of EIAs required for sub-projects - EIA/ EMP review - Issuance of environmental permits

1. local councils for protection and improvement of the environment 2. Environment protection councils at KRG governorates

Perform field inspections and monitor actual implementation of Environmental Management Plans (EMPs) on the ground, as well as apply a fine system against environmental violations

1. Environment Protection and Improvement Council. 2. Environmental protection and improvement committee at governorates of the KRG

Coordination between local environment protection councils and authorities (municipalities, governorates, labor and social directorates, etc.)

Health Directorates (central government and KRG)

- Monitor communicable diseases - Provide vaccinations to workers and the hosting communities, - Provide medical care to all community members through local

health care centers and programs - Provide awareness programs to communities

Labor and Social Affairs Directorates (central government and KRG)

- Overseeing local labor markets - Monitoring violations to labor according to the labor law - Field inspection for illegal workforce (including child labor) - Field inspection for Occupational Health and Safety measures - Processing applications for various assistance programs (job

opportunities, livelihood assistance, microfinance, cash support, etc.)

4.4. Applicable World Bank Policies The Project will include some civil work activities under Component 1, through which site-specific, small-scale, and reversible environmental and social impacts can be expected. The Project has already been classified as Category “B” according to OP/BP 4.01 Environmental Assessment. Only three Bank’s operational policies were triggered: OP/BP 4.01 Environmental Assessment, OP/BP 4.11 Physical Cultural Resources, and OP/BP 4.12 Involuntary Resettlement. The subsequent sections provide an overview to the requirements of OP/BP’s 4.01, 4.11, and 4.12, however, the Bank’s policies for Investment Project Financing, Accessing Information, and the IFC’s Guideline for Environmental Health and Safety would apply throughout the implementation of the Project.

Investment Project Financing, OP/BP 10.00 – 2013

Investment Project Financing supports projects with defined development objectives, activities, and results, and disburses the proceeds of Bank financing against specific eligible expenditures. The Bank’s assessment of the proposed Project is based on various country and Project-specific


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considerations including consistency with the Bank’s strategy in support of the country, Project development objectives, that take into account technical, economic, fiduciary, environmental, and social considerations, and related risks.

The Project is being processed under Section III, Paragraph 12 of the Bank Policy: Projects in Situations of Urgent Need of Assistance or Capacity Constraints. For Investment Project Financing, the borrower prepares the project’s scope, objectives, and the borrower’s contractual rights and obligations, like carrying out the project in due diligence, maintain appropriate implementation monitoring and evaluation arrangements, and comply with procurement, financial management, disbursement, social and environmental obligations. However, the Bank appraises the project in accordance with OP/BP 10 and other applicable polices, additionally, the Bank monitors compliance and provides implementation support through reviewing progress.

The World Bank Policy on Environmental Assessment, OP4.01 – 2013

This OP/BP 4.01 of the World Bank sets objectives, triggers, and implementation mechanisms, which in whole constitute the overarching safeguard policy to identify, avoid, and mitigate the potential negative environmental and social impacts associated with the Bank's lending operations. In the World Bank operations, the purpose of Environmental Assessment (EA) is to improve decision making, to ensure that project options under consideration are sound and sustainable, and that potentially affected people have been properly consulted. The borrower is responsible for carrying out the EA and the Bank advises the borrower on the Bank’s EA requirements. The Bank classifies the proposed project into three major categories, depending on the type, location, sensitivity, and scale of the project and the nature and magnitude of its environmental impacts. These are as follows:

− Category “A”: The proposed project is likely to have significant adverse environmental impacts that are sensitive, diverse, or unprecedented. These impacts may affect an area broader than the sites or facilities subject to physical works.

− Category “B”: The proposed project’s potential adverse environmental impacts on the human population or the environmentally important areas-including wetlands, forests, grasslands, or other natural habitats- are less adverse than those of Category “A” projects. These impacts are site-specific; few of them, if any, are irreversible; and in most cases, mitigation measures can be designed more readily than Category "A" projects.

− Category “C”: The proposed project is likely to have minimal or no adverse environmental impacts.

Physical Cultural Resources, OP/BP 4.11 – 2013

Physical cultural resources are defined as movable or immovable objects, sites, structures, groups of structures, and natural features and landscapes that have archaeological, paleontological, historical, architectural, religious, aesthetic, or other cultural significance. Their cultural interest may be at the local, provincial or national level, or within the international community. Physical cultural resources are important as sources of valuable scientific and historical information, as assets for economic and social development, and as integral parts of a community's cultural identity and practices. The Bank assists countries to avoid or mitigate adverse impacts on physical cultural resources from development projects that it finances. The impacts on physical cultural resources resulting from project activities, including mitigating measures, should not contravene either the borrower's national legislation, or its obligations under relevant international environmental treaties and agreements. The borrower addresses impacts on the physical cultural resources in projects proposed for Bank financing, as an integral part of the environmental assessment process.


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As Iraq is rich in Physical/ Cultural Resources, and the destruction experienced during the conflict is likely to have affected historical buildings, religious sites such as mosques, and shrines, and monuments, the OP 4.11 is triggered as a precautionary measure and mitigation measures/chance find procedures are elaborated on in this ESMF.

Involuntary Resettlement, OP/BP 4.12 – 2013

This Policy is triggered in situations involving involuntary taking of land and involuntary restrictions of access to legally designated parks and protected areas which result from a Bank-assisted investment project. In particular, OP/BP 4.12 covers the following scope:

1. Involuntary taking of land resulting in: relocation or loss of shelter; loss of assets or access to assets; or loss of income sources or means of livelihood, whether or not the affected persons must move to another location; or

2. The involuntary restriction of access to legally designated parks and protected areas resulting in adverse impacts on the livelihoods of the displaced persons.

The Policy aims to avoid involuntary resettlement to the extent feasible, or to minimize and mitigate its adverse social and economic impacts. It promotes participation of displaced people in resettlement planning and implementation, and its key economic objective is to assist displaced persons in their efforts to improve or at least restore their incomes and standards of living after displacement. The policy prescribes compensation and other resettlement measures to achieve its objectives and requires that borrowers prepare adequate resettlement planning instruments prior to Bank appraisal of proposed projects.

The World Bank Policy on Access to Information – 2013

In addition to the safeguards policies, the Access to Information Policy is also relevant. To promote transparency and facilitate accountability, Bank Access to Information Policy supports decision making by the Borrower and the Bank by allowing public access to information on environmental and social aspects of projects in an accessible location and understandable form and language to key stakeholders. The Bank ensures that relevant project- related environmental and social safeguard documents, including the procedures prepared for projects involving subprojects, are disclosed in a timely manner before project appraisal formally begins. The policy requires disclosure in both English and the local language and must meet the standards of the World Bank.

Environmental Health and Safety Guidelines – 2008

The Environmental, Health and Safety (EHS) Guidelines, of the World Bank Group (WBG)/ International Finance Corporation (IFC) 20081, are the safeguard guidelines for environment, health and safety for the development of the industrial and other projects. They contain performance levels and measures that are considered to be achievable in new facilities at reasonable costs using existing technologies. When host country regulations differ from the levels and measures presented in the EHS Guidelines, projects are expected to achieve whichever is more stringent. If less stringent levels or measures than those provided in these EHS Guidelines are appropriate, in view of specific project circumstances, a full and detailed justification for any proposed alternative is needed as part of the site-specific environmental assessment. This justification should demonstrate that the choice for any alternative performance level is protective of human health and the environment. Section 4 of EHS

1 WBG EHS General Guidelines is available on: http://www.ifc.org/wps/wcm/connect/554e8d80488658e4b76af76a6515bb18/Final%2B-%2BGeneral%2BEHS%2BGuidelines.pdf?MOD=AJPERES

http://www.ifc.org/wps/wcm/connect/554e8d80488658e4b76af76a6515bb18/Final%2B-%2BGeneral%2BEHS%2BGuidelines.pdf?MOD=AJPERES

http://www.ifc.org/wps/wcm/connect/554e8d80488658e4b76af76a6515bb18/Final%2B-%2BGeneral%2BEHS%2BGuidelines.pdf?MOD=AJPERES


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Guidelines for “Construction and Decommissioning” provides additional and specific guidance on the prevention and control of community health and safety impacts that may occur during a new project development, at the end of the project life-cycle, or due to expansion or modification of existing project facilities.

4.5. Gaps Analysis The Project is financed by the World Bank, which entails fulfillment of environmental and social safeguards issued by the World Bank Group. Once E&S safeguards have been fulfilled, the financial assistance will be authorized for the borrower accordingly. At the same time, the Project needs to be approved locally from the Iraqi Ministry of Health and Environment (including KRG Board for Environmental Protection), which by the Law, is responsible for screening projects, reviewing E&S studies, and accordingly issuing certificate of environmental compliance. However, the Project includes a variety of interventions that are different in impact type and magnitude, yet not well-defined in terms of boundaries and blueprints. The preparation of a framework management document would be the best safeguards instrument at this stage. Iraqi/KRG legislations do not include the provision for preparing an Environmental and Social Management Framework (ESMF), while the Bank does (OP/BP 4.01)

Under the requirements of the WB, this Project was screened as category B, should the new interventions, in general, have less significant and site-specific impacts on the surrounding environment. However, the WB's requirements for category B projects would entail the undertaking of a public consultation, in order to share views with Project Affected Persons (PAPs) before commencing the Project; to collect feedback about the most pressing environmental and social areas to be assessed; and to put the most feasible and sound mitigatory measures that would ensure best attenuation of adverse impacts. A public participation requirement for development projects in Iraq is neither explicitly mentioned in the aforementioned Iraqi EIA instructions, nor is it referred to in the Iraqi Laws 37 and 27 (including KRG’s Law no. 8). This would also constitute another shortcoming. Conducting a public consultation for this project would fulfill WB's requirements and consequently would not cause any conflict with the Iraqi legislative system.

Although subprojects (especially those of Component 1) planned under this SFDP will not involve involuntary taking of land or involuntary resettlement, yet there could be some minor social, economic, and cultural impacts. Therefore, OP/BP 4.12 is triggered as a precautionary measure, and a Resettlement Policy Framework (RPF) is prepared. This RPF includes useful information to guide through addressing any unexpected impacts of the Project. The Iraqi "Acquisition Law no. 12" does not provide enough means for restoration. By the Law only people having the legal right on land/property are entitled, which highlights another shortcoming of the Iraqi framework.

With respect to disclosing ESMF study findings, the Bank requires the disclosure of the ESMF findings to the public in an accessible way and by using a language fairly understandable by the target community. This is attained through providing a non-technical summary of the study (officially referred to as an Executive Summary) in the same language as of the receiving community. The WB would also publish the whole ESMF study on its external websites. This requirement is adequately covered in both "Environmental Assessment OP/BP 4.01" and "The World Bank Policy on Access to Information" of the World Bank Group. There is no clear mentioning on the need to disclose the findings of environmental and social studies publicly, by the Iraqi framework. And it does not specify how such information could reach the community’s attention.


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The following Table may provide key differences of E&S framework requirements between the WB's and Iraqi legislative systems.

Table 7: Summary requirements of the WB's and Iraqi ESMF

ESMF Requirements

Level of E&S Study

Public Participation Involuntary Resettlement ESMF Disclosure

WB's ESMF/ ESMP

Fairly presented in OP/BP 4.01

Fairly presented in OP/BP 4.12

Fairly presented in OP/BP 4.01 and Policy on Access to Information

Iraqi No provision for preparing ESMF at this stage

Not presented Not presented Not presented

Action Proposed

Proceed with ESMF report according to the provisions of OP/BP 4.01

Proceed with a public consultation meeting/ interviews

Prepare RPF according to OP/BP 4.12

Disclose through a public consultation/ WB’s external websites


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Chapter 5: Environmental and Social Impacts Framework

5.1. Risk Identification Assessing and studying Risks are quite important for dealing with hazards and hazardous events, and eventually avoiding harm. Generally speaking, Risk Assessment is the process that identifies hazards, their severity, and how likely they are to occur. Risk assessment as such, is a useful tool for determining protective and preventive measures to manage hazards. For instance, many industries involve Occupational Health and Safety (OHS) related risks. Management options – as proposed by IFC’s guideline for Environmental Health and Safety – Include the following according to priority:

− Eliminating the hazard by removing the activity from the work process. Examples include substitution with less hazardous chemicals, using different manufacturing processes, etc;

− Controlling the hazard at its source through use of engineering controls. Examples include local exhaust ventilation, isolation rooms, machine guarding, acoustic insulating, etc;

− Minimizing the hazard through design of safe work systems and administrative or institutional control measures. Examples include job rotation, training safe work procedures, lock-out and tag-out, workplace monitoring, limiting exposure or work duration, etc. and

− Providing appropriate personal protective equipment (PPE) in conjunction with training, use, and maintenance of the PPE.

The application of prevention and control measures to occupational hazards should be based on comprehensive job safety or job hazard analyses. The results of these analyses should be prioritized as part of an action plan based on the likelihood and severity of the consequence of exposure to the identified hazards.

The Project Appraisal Document (PAD) has ranked the combined risk for environmental and social aspects as “Substantial” mostly due to social risks, but to a lower degree to environmental aspects. The document has also highlighted general risks associated with implementing all components, addressing different areas; political and governance, macroeconomic, the technical design, institutional capacity and sustainability, as well as fiduciary. These all aspects have raised the overall risk of the Project to High.

For Component 1, the key social challenges are associated with the process of identification and selection of working groups in their areas, the effective representation and participation especially for the underprivileged subpopulations, the perception of unfair distribution of services, and eventually what could be achieved for regaining trust with the government. Other risks are operational ones, like delays in implementing subproject activities and poor quality. And risk of lacking security in project areas. Additionally, risks can be related to involuntary taking of land during project implementation and lack of compensation for project affected persons (PAPs), though low and temporary in nature. Furthermore, risks may include the potential of child/forced labor or issues connected to labor influx.

On another hand, environmental risks are considered low, and can be related to OHS (i.e. working in heights, exposure to working materials, either for cleaning, painting, or even exposure to working tools, and hard/ sharp objects); community health and safety; contamination of the physical environment (dust, noise, runoffs, waste, etc.); endangering the biological sensitive environments; as well as the risk of damaging cultural/ historical heritage, including chance finds.


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The Component 2 of microfinance will also include some socio-economic risks, such as; inflating the market and distorting prices, marketing challenges (supplies and demand), as well as risk of increasing financial burden on borrowers.

The above risks, if occurred, will have negative/adverse impacts on Project Affected Persons (PAPs) as well as on the surroundings, though varying in significance and magnitude. For the sake of this ESMF, a range of negative impacts were identified according to the Project design, and in consultations with stakeholders and PAPs. The subsequent sections will provide more information on impact assessment methodology, feedback collected from public consultations/ interviews and proposed management measures.

5.2. Impact Assessment Methodology Impacts under this study include environmental and social/ socio-economic ones. These are a collection of expected effects during implementation of the Project identified up to this stage. Impacts include either positive or negative (adverse), however, this section will focus on negative impacts of the environmental and socio-economic aspects within the boundaries of the Project interventions, in this case all 18 governorates of Iraq. As for positive impacts, these were highlighted in the Project Description Chapter. The following would provide guidance on identifying and rating impacts for the Project:

1. Identifying environmental and social aspects: these are the set of sensitive receptors of the negative effects from the various project interventions. And they could be identified through understanding the different interactions expected to result from project phases: planning, constructing, operating, decommissioning. For instance, air pollution, is one negative impact to be expected if a project activity is to emit dust and gaseous constituents. Also health issues on workers are to be considered, if a project activity would involve exposure to dangerous tools, hazardous materials, and many others. Usually impacts are identified by subject matter experts, and the experience collected in a certain area of specialty. As for the SFDP, the following resources were leveraged in order to provide a potential E&S impact account for the Project during the course of implementation:

− All applicable laws, regulations, instructions, decrees and safeguards put in place either by the Iraqi government, or by the financing agency the "World Bank Group", including those guidelines of International Finance Corporation (IFC), as well as other international conventions and guides deemed recognizable;

− Environmental and social baseline data for the Project’s geographical areas;

− Design and implementation approaches of the Project;

− Public consultations/ interviews at the central and provincial levels;

− Literature review of similar interventions; and

− Practical experience in the field of Environmental and Social Assessment and Management.

2. Rating impacts: this is performed using descriptive words to describe severity/significance of impacts, including:

− Highly, moderately, low significant (minor), or no significance/ no impact.


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− Direct or indirect. As some impacts would directly affect receptors, such as high levels of dust would cause respiratory issues. Or the impact could be received via other means, such as pollutants possibly entering water bodies, and finally affect human health in the end

− Short-term, medium-term, or long-term. This is a way to describe the time period when impacts could appear. For instance, soil erosion can be observed in the long term upon cutting trees, while traffic congestions can be observed in the short term upon a road closure.

− Cumulative, or noncumulative. This is used when negative impacts are expected to increase severity/significance with time. For instance, heavy metals can have a cumulative effect (elevated concentrations) on crop consumers upon polluting fertile lands as time elapses.

3. Consulting on impacts. This will be needed to gain consensus on the expected impacts, to be able to rate them using others’ experiences, and to eliminate/add impacts as a result of a consultation feedback.

4. Mitigating, managing, and monitoring impacts: these are advanced stages performed on impacts, which would include proposing best mitigation measures/ best management practices, responsibilities and resources for managing impacts, as well as devices/tools, programs for monitoring impacts and ensuring they do not exceed allowable limits.

5. Revisiting impacts. During the lifecycle of the project, impacts could be re-analyzed through an expert lens, resulting in increased or lessened level of significance. Impacts can change severity or magnitude if receiving environments change, or be induced by other investments in the area.

The above steps are generic for assessing negative impacts. As for the SFDP, Component 1 will include small-scale civil works, which would entail the preparation of site-specific ESMPs. At that detailed stage of the Project, the sub-project’s proponent/ contractor/ implementing agency should re-assess impacts taking into account the site-specific characteristics, and building on feedback collected from beneficiary communities and E&S specialists in their area of specialty. However, impacts should be described for both construction and operation phases, as appropriate.

The following section presents an E&S register for expected negative impacts during SFD’s implementation phase:

5.3. Expected Adverse Impacts – overview The SFD Project has been designed to help reinstate and reintegrate post-conflict returnees, IDPs, and vulnerable groups in all target regions of Iraq. However, some interventions of the program could result in negative effects, though, minor, site-specific, and reversible. Of particular concern are impacts expected from the limited infrastructural civil works (Component 1). While information is limited on the design of the activities at this stage, impact rating has taken into consideration construction and operation phases, rather focused on the construction phase.

The following are general discussions to the Project components and their relevant impacts (socio-economic, health and safety, environmental, and cultural heritage).


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Health and safety impacts

1. Occupational health and safety issues: These include over-exertion, slipping, falling from heights, getting stuck by objects, having electrical shocks and/or respiratory problems. Community members (the majority of Project beneficiaries) are considered ones of the most sensitive receptors of hazards during implementation of Component 1 activities. Work packages will include renovation of public buildings, and rehabilitation of roads, water networks, health centers, school buildings, which are not specified at this stage of the study. Risk includes injuries and health impacts related to Occupational Health and Safety (OHS) through performing the small-scale civil works. Impacts are foreseen moderate, direct; and in the short term, however, impacts can be managed by managing site and applying protective gear, amongst others.

2. Community health and safety issues (pests & diseases, excavation, dust & noise, heavy traffic): the surrounding communities, who are not directly involved in the Project interventions can also receive health impacts (mainly respiratory ones), as traffic and excavation could deteriorate quality of ambient air. Specifically, this will increase levels of particulate matter and gaseous emissions in the surrounding environment. Impacts also include stress and discomfort due to rising of noise levels beyond allowable limits as a result of using electrical and mechanical equipment. Health injuries connected to traffic accidents could also be significant, as transport of equipment and labor influx is expected to increase. Health issues of disease and pests spreading are also expected, due to accumulation of various materials at worksite including wastewater and solid waste. All of these health impacts on community are considered moderate, direct, and in the short term. Impacts from Worksites can be jointly planned by contractors in close coordination with the Project Management and responsible authorities (for instance, relevant municipalities, environment and health directorates, traffic department).

Environmental impacts

3. Pollution of the surrounding environment: civil works would typically result in some impacts on the surrounding environment, which may include: wastewater effluents from worksite, solid waste accumulation, oil spills, runoff, sediments, deterioration of air quality and increasing noise levels. Pollutants will have adverse impacts on soil and air, and would contaminate water resources. Impacts are considered moderate, direct, and indirect, in the medium to long term. However, impacts can be alleviated by following best management practices, and housekeeping, amongst others.

4. Endangering biological life: Biological species are ones of the sensitive receptors of hazards in the area. As explained in the biological life setting, the wider area of Iraq includes many species of concern, birds, marine fish, and marshlands, amongst others. However, the impact is considered moderate, direct and indirect, in the medium to long term, as activities will be mostly designed and implemented in urbanized areas. Several precautionary measures can be proposed in this regard.

Cultural heritage impacts

5. Possible damage to objects of historical/ cultural value: some work would involve renovation of sites and performing some light excavations. Due to the fact that Iraq is rich in cultural and historical sites, there would be some minor impacts expected on objects of historical/ cultural


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value. During works that involve excavation, or replacement of damaged networks, chance finds may come across. Looting and damaging of objects of cultural value are also possible. Impacts on historical and cultural heritage are foreseen moderate, direct, and in the short term, however, can be managed through putting in place suitable measures and clear site procedures in close coordination with the responsible authorities.

Socio-economic Impacts

6. Unfair representation of the underprivileged/ disadvantaged subgroups: these impacts would typically appear after work packages have been identified in target communities. These vulnerable groups may not have the power to voice their demands, or participate in planning for work in their home territories. The Project has put in place a number of measures for planning and increasing participation by teaming up with experienced Non-Governmental Organizations (NGOs), Civil Society Organizations (CSOs) in the field, as well as hiring social specialists where needed. To this end, impacts are expected moderate, indirect, and in the medium term.

7. Social/community conflict and insecurity: beneficiary communities may have rising tension due to many reasons, some of which are related to tribal or geographical/geopolitical domination in the area. These effects could be evident while work packages are being selected and after they have been offered for implementation. Moreover, insecurity impacts could be encountered on the ground, which may include attacking storage/supply/operations areas. Rising tension and lacking enough security are ones of the impeding factors for implementing the desired development. Therefore, impacts would be expected moderate, both direct and indirect, in the short term.

8. Work-related issues: These impacts could include child labor, forced labor, unpaid work, and inappropriate working conditions. Community work would most probably involve child labor, especially in the context of conflict, given the poor surveillance in the labor market, and the urgent need for work. According to labor law no. 37 for the year 2015, minimum working age is 15, as this aimed to prevent any discrimination or harassment to children, whether direct or indirect. This impact is considered moderate, direct, and indirect, and in the short term. However, mitigation could turn this into minor. Measures involve: increasing control over labor market, by regular inspections, and putting more stringent employment terms on contractors, and business owners, and enforcing the penalty system.

9. Labor influx issues: these effects would be more visible during the course of implementing civil works (Component 1). Rehabilitation places will witness a higher existence of laborers than nearby places, including job seekers, which might lead to some disturbance to the normal life and cause nuisance to the hosting community. This would possibly include spreading of communicable diseases as well, especially if nonlocal workers are engaged. The impact is foreseen moderate, direct, and in the short term. Management measures would include designating working places far enough from populated areas; regulating working hours, and providing clear instructions on the movement around the area. Laborers should be subjected to health monitoring, including vaccination where necessary. And the planning for different work packages should only consider local participation, with help from relevant NGOs and CSOs.

10. Discrepancy/ poor selection for jobs based on ethnicity, religion, culture, physical fitness, gender, age: these effects are attributed to poor selection of beneficiaries by lacking proper techniques for targeting and selection. This would also arise from responsible NGOs/ CSOs and field staff being not trained enough for this type of humanitarian aid (i.e. lacking enough capacity to apply


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instructions/ procedures in the field). Impact is expected moderately significant, indirect, and in the medium and long term. Mitigation may include: 1. Monitoring through unannounced visits, field reporting, and pursuing advice from program management. 2. Using reliable mechanisms for data capturing; 3. Adopting a mixed targeting approach, by considering poorest locations with highest numbers of potential beneficiaries, IDPs, and returnees within target governorates, 4. Assessing the poor under existing databases at MOP and MOLSA.

11. Land acquisition related issues: during the life of the project, voluntary land donation (VLD) is envisioned as a contribution by the community with no pressure and will only be eligible if a consent form is signed and attached to the subproject. These lands would generally be allotted for material storage, work preparation/ dispatching, and/or as buffering zones around buildings/ lands under rehabilitation and clearance. In this context, impacts would include: 1. temporary land acquisition for establishing contractors’ camps and storage areas for equipment; 2. relocation of encroachers or IDPs due to sub-project activities; and 3. interruption and/or restriction to access any business adjacent to subprojects causing loss of assets, income and livelihood. Impact is considered minor, direct, indirect, and in the short term, as the Project will pursue state-owned lands and public properties for supporting work to the extent possible. Mitigation: the World Bank Policy on Social Safeguards ‐ OP 4.12 will be triggered as a precautionary measure.

12. Lack of/ insufficient compensation for Project Affected Persons (PAPs): this effect is connected to loss of land/ property, livelihoods, access to resources, relocation, amongst others. Fair compensation through local legislations are not well stipulated, especially in case of PAPs not having the legal title to their lost property. Impact is expected moderate and direct, in the short and medium terms. However, the Project Management should address this shortcoming through following instructions of the WB (OP/BP 4.12) which requires the preparation of a Resettlement Action Plan (RAP) or an Abbreviated Resettlement Action Plan (ARAP) including surveys and compensation plans.

13. Inflation and price distortion in local markets: for programs that involve community work, it is essential to inject needed cash flow into the local economy without causing unwanted economic ramifications such as price fluctuation, dependency, or competition with local producers. During the implementation of the program (Component 1), a great care should be taken in setting the wage rate for laborers, as this would have negative impacts on local markets. If wage rates are higher than the market rate, working opportunities may entice people away from their regular livelihood activities. Also, different wage rates among similar work programs may affect the market negatively and cause disputes among communities. Other factors that could contribute to the market distortion are the labor competition between existing businesses and fluctuation of prices of basic commodities. These impacts are foreseen moderately significant, indirect, and in the long term.

14. Poor supplies and poor demands for products and services in businesses’ locations: the impact is considered moderate, indirect, and in the medium and long terms. Mitigation measures may include providing enough information to beneficiaries of Microfinance, and promoting local products.

15. Increasing debt burden: this would be expected if beneficiaries fail to generate sufficient income to support their families, and pay back the micro-loan. The impact is considered moderate, direct, and in the medium to long term. Mitigation include increasing marketing for local products, and facilitating pay back.


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The following Table summarizes impacts and their relevant assessment.

Table 8: Summary impacts and rating for this ESMF

Impacts Rating

Component 1: Financing Community Sub-projects Health and safety impacts 1 Occupational health and safety issues Moderate, direct, and in the short term 2 Community health and safety issues Moderate, direct, and in the short term Environmental impacts 3 Pollution of the surrounding environment Moderate, direct, and indirect, and in the

medium to long term 4 Endangering biological life Moderate, direct and indirect, in the medium

to long term Cultural heritage impacts 5 Possible damage to objects of historical/ cultural value Moderate, direct, and in the short term Socio-economic impacts 6 Unfair representation of the underprivileged/

disadvantaged subgroups Moderate, indirect, and in the medium term

7 Social/community conflict and insecurity Moderate, both direct and indirect, in the short term

8 Worker-related issues Moderate, direct, and indirect, and in the short term

9 Labor influx issues Moderate, direct, and in the short term 10 Discrepancy/ poor selection for jobs based on ethnicity,

religion, culture, physical fitness, gender, age Moderate, indirect, and in the medium and long term

11 Land acquisition-related issues Minor, direct, indirect, and in the short term 12 Lack of/ insufficient compensation for Project Affected

Persons (PAPs) Moderate and direct, in the short and medium terms

Component 2: Supporting Microfinance Systems 13 Inflation and price distortion in local markets Moderate, indirect, and in the long term 14 Poor supplies and poor demands for products and

services in businesses’ locations Moderate, indirect, and in the medium and long terms

15 Increasing debt burden, fail to generate sufficient income to support their families, and pay back the loan

Moderate, direct, and in the medium to long term


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Chapter 6: Public Consultation and Engagement

6.1. Stakeholders’ Consultation The Public consultation in general aims at introducing various interventions during the lifetime of the Project to the Project Affected Persons (PAPs), to enable discussing possible environmental and social impacts in a transparent way; and to collect views on how to strengthen opportunities and diminish adverse consequences brought about by the Project.

Although the Project targets all Iraqi governorates (spanning five years), only three governorates will start receiving support during the first year, these are Muthanna, Salahiddin and Dohuk. However, public consultations were initiated in Al Muthanna and Salahiddin Governorates in December 2018, and then followed with two public gatherings in Dohuk in January 2019. Moreover, consultations should be pursuit for the 4 governorates of Baghdad, Qadisiya, Thiqar, and Ninawa, in the second year. The remaining 11 governorates should be consulted throughout the remaining period of the Project.

For the sake of preparing this ESMF, the study team has used a pre-designed questionnaire to collect views from participants. The questionnaire applied in the field was intended to be simple, straightforward, and written in the local language (Arabic). The Questionnaire begins with providing basic information about the Project, and its various components. Questions have concentrated on social and environmental impacts, but with more emphasis on social/socio-economic aspects, as expected from carrying out activities of Components 1 and 2. More specifically, questions intended to collect views on impacts expected from the small-scale infrastructural activities in Component 1, including impacts on the surrounding environment and worksite hygiene, while more focus has been given to socio-economic issues expected from work packages, labor involvement, community conflicts, and most importantly issues related to involuntary resettlement and concerns of unfair compensation. The Questionnaire has also provided additional space for interviewees to express general interests and concerns about the Project. Annex II provides a copy of the questionnaire as well as the participants’ list.

The approach (the Questionnaire) was chosen for carrying out consultations to avoid public gathering or conducting big meetings, as the target areas are still living insecurity conditions. Additionally, the Questionnaire saved time, money, and effort that would be spent for setting up a bigger public meeting place. However, conditions were comparatively much better in Dohuk that enabled the team of MOP of KRG to coordinate two successful public meetings in two villages of Dohuk. The following Table provides primary information about participants in Al Muthanna, Salahiddin, and Dohuk governorates:

Table 9: Participants of the consultation interviews Area Date(s) of

interviews Number of participants

Gender Marital status Educational level Profession

Al Muthanna governorate, Al-Warka’ District + Al-Helal Nahiya

14-18 Dec 2018

141 Male: 141 Female: 0

Married: 101 Single: 8 No answer: 32

Illiterate: 18 Literate: 7 Primary school: 50 Middle school: 10 Diploma: 11 Undergraduate: 8 No answer: 37

Laborer: 98 Civil service: 13 Military: 9 Businessman: 5 Teacher: 2 Retired: 3 Other: 8 No answer: 3

Salahiddin, Al-Alam District

14-18 Dec 2018


Married: 107 Single: 8 No answer: 0

Illiterate: 1 Literate: 4 Primary school: 21

Laborer: 42 Civil service: 15 Military: 20


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Area Date(s) of interviews

Number of participants

Gender Marital status Educational level Profession

Middle school: 14 Diploma: 35 Undergraduate: 36 Graduate/post-graduate: 3 No answer: 1

Teacher: 17 Retired: 9 Other: 11 No answer: 1

Dohuk Baadre Nahiya + Bebava Village/ Qusrok Nahiya

23 January 2019 29 January 2019


- A Mixture of University graduates Middle school And illiterate people

A mixture of laborers, farmers, teachers, civil service staff, and others

Interviewees were asked to read and rate the expected environmental and social impacts, which were preceded with necessary explanations from social specialists in the field. Interviewees were given enough ahead of information on the Project, its components, and the key expected benefits, in order to ensure good level of understanding and feedback. The following Table presents answers, percentages, and overall rating of impacts. Results came in good agreement with the rating of impacts suggested in Chapter 5.

Table 10: E&S impact rating by public consultations – Al Muthanna, Salahiddin & Dohuk

Impacts Governorate Rating Overall

Significance I strongly agree I agree I doubt

it I disagree

Component 1 – Financing Community Sub-projects 1 This part of the Project will provide many

opportunities to rehabilitate basic service facilities and create jobs for the people through small-scale civil works, but do you think workers will be exposed during their work to: stress, slippage, falls from heights, injuries, electric shocks, respiratory problems, and others?

Muthanna 11

7.8%

48

34.0%

81

57.5%

1

0.7%

Minor

Salahiddin 0

0.0%

1

0.9%

112

97.4%

2

1.7%

Minor

Dohuk - 123

100%

- - Medium

2 The Project will improve the quality of the basic services and infrastructure for the local community, including cleaning and maintenance of drainage channels along the roads, in addition to cleaning and rehabilitating irrigation channels and the agricultural and ancillary roads, but do you think the community will be exposed to dust and noise, traffic congestions, or spreading of diseases as a result of these activities?

Muthanna 5 3.5%

39 27.7%

91 64.5%

6 4.3%

Minor

Salahiddin 0 0.0%

2 1.7%

70 60.9%

43 37.4%

Minor

Dohuk - 123 100%

- - Medium

3 The contractor, who will carry out the maintenance and civil works, will be charged with a site-specific Environmental and Social Management Plan to preserve the work environment and the surrounding physical and biological environment, reduce pollutants and monitor their levels, including: gaseous and dust emissions, noise, wastewater disposal, solid waste accumulation, oil spillage and soil/water pollution. Do you expect these actions to be adequate and effective?

Muthanna 50 35.5%

81 57.4%

9 6.4%

2 1.4%

Minor

Salahiddin 38 33.0%

57 49.6%

18 15.7%

2 1.7%

Medium

Dohuk - 123 100%

- - Medium

4 Strict terms and conditions will be imposed on contractors during their implementation

Muthanna 49 34.8%

24 17.0%

63 44.7%

5 3.5%

Medium


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it I disagree

of small-scale civil works, concerning interfering with the surrounding environment. However, biological life (animals, birds, plants, and riparian species) could still be impacted. What do you think?

Salahiddin 6 5.2%

3 2.6%

89 77.4%

17 14.8%

Medium

Dohuk - 123 100%

- - Minor

5 It will be stressed and made liable for the contractors and workers from the local community to avoid damage/vandalism to historical, archaeological sites, monuments, chance finds, looting of antiquities, consequences of noncompliance, and the need to report instantly. Do you think these measures would be enough?

Muthanna 26 18.4%

99 70.2%

14 9.9%

2 1.4%

Moderate

Salahiddin 60 52.2%

53 46.1%

1 0.9%

1 0.9%

Minor

Dohuk 123 100%

- - - Minor

6 Community organizations, who will represent the voice of various segments of the community, including marginalized and vulnerable groups (the poor, women, the elderly, the disabled, and people with special needs), will ensure their participation in the selection and planning of subproject activities and their fair and adequate representation, What do you think?

Muthanna 53 37.6%

84 59.6%

4 2.8%

0 0%

Medium

Salahiddin 8 7.0%

105 91.3%

0.0% 2 1.7%

Medium

Dohuk 123 100%

- - - Minor

7 It is expected that strict terms and conditions will be established with contractors for the small-scale civil works, in addition to diligently supervising work onsite. This will ensure the quality of the work, punctuality, provision of all necessary materials, fair distribution of rehabilitation works among the affected communities, and increased level of communication, as well as consultation with members of the community. Are you satisfied with these measures?

Muthanna 88 62.4%

44 31.2%

6 4.2%

3 2.1%

Minor

Salahiddin 88 77.2%

12 10.5%

2 1.8%

12 10.5%

Minor

Dohuk 123 100%

- - - Minor

8 The Iraqi laws clearly stipulate rights of workers, including rights for fair remuneration, and provision of appropriate working conditions, as well as prohibition of forced labor and child labor. Do you expect these problems to arise despite the existence of laws and penalties?

Muthanna 18 12.8%

46 32.6%

72 51.1%

5 3.5%

Minor

Salahiddin 0 0.0%

15 13.0%

88 76.5%

12 10.4%

Minor

Dohuk 123 100%

- - - High

9 This Project is mainly aiming at providing jobs for members of local communities affected by recent conflicts. Therefore, local people will be hired, in addition to providing working areas as far away from the residential areas as possible. Nevertheless, do you expect non-locals to take jobs in the Project, transmit diseases, or cause nuisance to hosting communities in nearby places?

Muthanna 65 50.0%

42 32.3%

22 16.9%

1 0.8%

High

Salahiddin 2 1.9%

67 62.0%

1 0.9%

38 35.2%

Moderate

Dohuk 65 52.8%

58 47.2%

- - Moderate

10 One of the Project’s key objectives is to provide job opportunities to members of affected communities based on fair selection of beneficiaries and social justice, regardless of ethnicity, religion, culture, physical fitness, gender, and age. What do you think?

Muthanna 30 22.2%

97 71.9%

8 5.9%

0 0%

Moderate

Salahiddin 46 40.4%

68 59.6%

0 0.0%

0 0.0%

Moderate

Dohuk 123 100%

- - - Minor


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it I disagree

11 The Project does not include taking of land or private property. But limited areas might be needed for work preparation and storage of materials, which will be mainly sought from state-owned properties. Although very unlikely, do you expect that this will result in: (1) relocation of encroachers/squatters; (2) loss of income or means of livelihood; and/or (3) loss of assets or access to assets, and interruption of daily life?

Muthanna 4 2.9%

16 11.7%

87 64.0%

29 21.3%

Minor

Salahiddin 0 0.0%

1 0.9%

111 96.5%

3 2.6%

Minor

Dohuk - 58 47.2%

65 52.8%

- Minor

12 Iraqi laws and World Bank’s regulations stress that Project Affected Persons are entitled to receive fair and adequate compensation. What do you think?

Muthanna 83 60.1%

50 36.2%

5 3.6%

0 0%

Minor

Salahiddin 44 38.3%

71 61.7%

0 0.0%

0 0.0%

Moderate

Dohuk - 123 100%

- - Moderate

Component 2 – Supporting Microfinance Systems 13 The Project will review the regulatory

environment to allow MFIs to operate in the market without causing inflation and price distortion in local markets. What do you think?

Muthanna 49 36.3%

68 50.4%

16 11.8%

2 1.5%

Moderate

Salahiddin 42 36.5%

68 59.1%

5 4.3%

0 0.0%

Moderate

Dohuk - 123 100%

- - Moderate

14 The microfinance system within this Project will put in place the proper environment to ensure the availability and smooth flow of supplies for business owners in their locations, and will also help create an appropriate commercial and marketing environment to encourage demand for local products and services. What do you think?

Muthanna 31 22.8%

99 72.8%

6 4.4%

0 0%

Moderate

Salahiddin 28 24.6%

86 75.4%

0 0.0%

0 0.0%

Moderate

Dohuk - 123 100%

- - Moderate

15 The Project will provide soft loans and fiduciary support that will increase the income of the beneficiary families and facilitate paying back the loan. What do you think?

Muthanna 79 60.3%

47 35.9%

5 3.8%

0 0%

Minor

Salahiddin 66 57.9%

47 41.2%

1 0.9%

0 0.0%

Minor

Dohuk - 123 100%

- - Moderate

In summary, the above feedback table shows a good level of confidence and optimism towards implementing the proposed activities of the SFDP. Most of the feedback has already predicted minor negative impacts on physical, biological, and cultural environments, community health, workers’ safety, working conditions, and site hygiene during implementation, in addition to engaging vulnerable/ marginalized groups in rehabilitation opportunities. However, participants seemed to be a bit concerned about how fair targeting and selection of beneficiaries of the project would be. Along with some expected issues in market prices, local market participation, and paying back micro loans. Higher concerns were observed with regard to labor influx, and the possibility to have rising levels of nuisance/ disturbance in the neighborhood as a result of carrying out rehabilitation activities. Most importantly, interviewees showed little concerns about involuntary taking of land, or encroachers/IDPs being displaced from occupied properties for the implementing the Project (if any). However, unfair compensation in return for loss of assets or access to livelihood means and resources could be an issue as per interviewees.


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The following are some photos from field consultations in Muthanna, Salahiddin, and Dohuk:

Muthanna and Salahiddin

Dohuk


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As aforementioned, interviewees had the chance to additionally express their thoughts on the Project. Notes focused on the urgent need for starting investments in infrastructure (water networks, electricity, roads, health care centers, etc.), and providing job opportunities for the unemployed, as well as enhancing living conditions. Interviewees have already emphasized the positive impacts of implementing developmental projects in remote areas and how this would lessen migration to cities. Notes also stressed on the need to have adequate planning of the Project’s activities and the importance to include all neighboring Nahiyas.

6.2. Stakeholders’ Participation Up to this stage of preparation, only the broader context of the Project’s design is known, thus, the Project would include a wide array of stakeholders, including MOP, implementing agencies and contractors, as well as project receiving communities and individuals. Nevertheless, the Project is designed to have small-scale sub-projects, which, upon finalization, should undergo impact assessment, and result in the preparation of site-specific ESMPs. As part of the preparation and clearance processes of these specific ESMPs, the contractors, or other implementing agencies (NGOs, CSOs), in general, should identify project-specific stakeholders, which would essentially include the marginalized groups and PAPs. Additionally, the Project Management Team should be able to set modalities for consultation and communication in order to ensure effectiveness and feedback collection. The public consultation part is key to completing the site-specific ESMPs according to requirements of the World Bank (OP/BP 4.01 & WB’s policy on access to information), and granting clearance eventually.

The following sections provide key guiding elements of a Stakeholder’s Consultation and Participation Plan (SCPP), which have been built on the broader context of SFDP’s stakeholders. This Plan needs to be revisited and tailored to each sub-project’s needs before commencement.

Identification of stakeholders

In order to define a communication process in line with local and WB’s EIA Regulation, several stakeholder groups that may be interested and/or affected by the Project development and implementation have been identified. There are a number of groups of people and social groups who are interested in the project on different levels. These may be described as following:

− People and groups who will be directly or indirectly affected by the Project: these could include a wide range of community members, vulnerable groups, social welfare institutions,


58

academic institutions, local business owners, suppliers, who will either be situated close to Project’s activities or could feel the broader effects in the medium and long terms.

− People and groups who may participate in the implementation of the Project; these could essentially include all participants in the rehabilitation programs, in addition to NGOs, CSOs, contractors, chain suppliers, and all members of the Project Management Team.

− People and groups who may have a possibility to influence and make decisions on implementation of the Project: these could include a wide range of stakeholders and decision makers, Ministry of Health and Environment, local government leaders, community leaders, community development groups, labor unions, environmental activists, CSOs, NGOs, state entities, as well as the direct proponent of the Project (MOP).

− Stakeholders who may be interested in the Project: those are stakeholders whom are not affected by the project development per se but may have an interest in the implementation of the Project: these would include other ministries within the GOI and KRG, and Micro Financing Institutions (MFIs).

Before starting implementation, the PMT should embark on identifying all stakeholders and how they connect to the sub-project activities. The stakeholders’ register should be prepared and revisited periodically and made readily available for public meetings and consultations.

The main groups of stakeholders identified so far are listed briefly as above. However, the list can be updated and modified in the course of the Project development based on coordination and feedback from intermediate agencies in the field.

Vulnerable Groups

The stakeholders’ list also targets vulnerable groups of the local community. Vulnerable groups are those who are more susceptible to the effects from project selection, socio-economic and demographic contexts, as well as the nature of the sub-project and the ability to take part.

The following would provide an overview of vulnerable groups identified within the context of this ESMF. Such vulnerable groups could include the following, amongst others:

− Unemployed women groups – because of cultural norms in Iraq which could limit their participation in decision-making and their employment opportunities over males;

− Youth and the unemployed – given that one of the key socio-economic challenges facing the conflict survivors in target governorates is unemployment, the consultations should aim to take into account their interests and concerns in particular.

− Children and the elderlies – special considerations should be taken for the inclusion of the elderlies in suitable types of work. Additionally, care should be taken to prevent child labor, i.e. extending development benefits without causing harm or resulting in illegal trafficking. These groups could be consulted through a suitable representative/ union.

− Persons with special needs and the handicapped – this group of people should be always consulted on the best methods (through their representatives) for their integration in the community, and how they could effectively participate in the Project. Appropriate methods for consultation should be tailored to their needs.


59

Given the various components and multi-location characteristics of the Project and its sub-projects, there are considered to be additional vulnerable groups which would require special consideration throughout the consultation process and which could include groups which are expected to be disproportionally affected by the project impacts.

Phases of engagement

Upon starting of Project interventions, there will be smaller packages of activities (sub-projects), which will need to undergo a preliminary Environmental and Social Impact Assessment (ESIA), formulated, consulted on, and cleared through the local system, yet they should fulfill the requirements of the WB’s OP/BP 4.01. Sub-projects under this Project are necessarily categorized as B. It is expected that no sub-project of category A be considered under this SFDP. However, Stakeholders and Public Affected Persons should be consulted at least once for any sub-project of category B. Consultations in this case can take the direct form through meetings, an ongoing form throughout the project life cycle, and a localized information sharing boards (notice/ bulletin boards). These are explained as following:

− ESIA/ESMP engagement on a site-specific level;

− Ongoing engagement; and

− Notice/ local bulletin boards

Stakeholders’ engagement for ESIA/ESMP preparation: the focus in this phase will be primarily gathering information and opinions from stakeholders. Engagement activities will therefore include interviews with stakeholders’ representatives (community leaders) and key information organizations (communities, authorities, academic institutions, CSOs, NGOs, and others) using one-on-one meetings, workshops, or smaller focus group meetings. During these meetings, the Project proponent should engage stakeholders in the following:

− Introduce the Project and ESIA process

− Identify potential impacts and issues that will be covered in subsequent phases

− Further identify stakeholders related to the Project

− Identify and gain access to relevant data for the baseline

− Gather opinions on the proposed sub-project and feed these into the assessment process

− Gather feedback on the development of management and mitigation measures of potential impacts

This type of meeting can also be tailored to disclose environmental and social management plants (ESMPs) after their preparation, but views collected are to be taken further and incorporated in a final draft ESIA report.

Consultation meetings should be designed in a way to maximize participation and collect feedback and notes. At MOP, the PMT will be responsible for organizing consultation meetings, and should therefore facilitate all possible means of communication, and publicize communication mechanisms clearly on the central and local levels (see below for communication mechanisms). Finally, non-technical summaries of the ESIA report should be prepared in local languages and be easily accessible by the local community.


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Ongoing engagement: this phase should apply to all implementation time period of the Project. This would include meetings at the local level, where community representatives/ local governorate committees convene with the Project Management Team on regular bases, to get updates and share interests and concerns of the Project activities. The Public Relations Department at MOP, the local governorates and municipalities, and MOP’s directorates in governorates can also be involved to provide a better outreach to PAPs, especially at the local level.

Notice/ local bulletin boards: This is a quite simple and informative approach to inform literate PAPs at the very local level about proceedings of the Project and job opportunities, important dates and contacts, as well as complaining procedures, and many others. This kind of notice boards can be displayed on walls and entrances of municipal departments, governorates, MOP’s directorates, and other means to be identified in consultation with community representatives. However, information attached should be prepared in local languages, and be easily accessed by visitors and updated regularly.

Communication Process and Methods

During Project implementation period, communication should be continuously maintained with the Project stakeholders and PAPs for providing consultation and updates and other purposes as mentioned above. Communication can be achieved through many mechanisms and approaches. The following Table suggests most appropriate communication mechanisms for different groups of stakeholders.

ESMF – Iraq Social Fund for Development Project -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

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Table 11: Identified stakeholders and most appropriate communication methods and tools

Level of Stakeholders’ Involvement

Objectives

Communication methods and tools

Group meetings

Individual/ Internal meetings

MOP’s Website/

social media

Project leaflets

in Arabic

Disclosure of documents at

Municipal/ governorate

level

Emails Local

bulletin boards

Correspondence & official letters

relating to project

Stakeholders who may be directly or indirectly affected by the project Community members

Component 1: - Ongoing reporting to provide regular updates

on project activities – e.g. details on locations of sub-projects, procurements, commencement dates, payments procedures and dates, and any changes to the above;

- Provide affected communities with information on Stakeholder Engagement Programs;

- Obtain feedback on the implementation of site-specific ESMPs and its various components.

- Inform local stakeholders about employment opportunities, required qualifications, employment procedures, job openings, and training opportunities;

- Grievance mechanisms and procedures.

X - X X X - X -

Social welfare institutions - X - X - X - X

Academic institutions - - - X - X - X

Local business owners - X - - X X X X

Suppliers - X - - X X X X Children & elderlies X - X - X - X -

Persons with special needs & the handicapped

X - X X - - X -

Stakeholders who may participate in implementation of the project Laborers (skilled, unskilled)

Components 1 & 2: - Schedules for service delivery - Procurements and requirements - Important dates for payments and other

important transactions - Micro finance transaction - GRM - TORs/Tender documents - Project updates - Tender documents and contracting procedures - Occupational Health and Safety Plans - Site-specific ESMPs

X - X X X - X -

NGOs, CSOs - X - - X X X X

Contractors - - X X - X X X X

Chain suppliers - X X - X X X X Project Management Teams

X X X X X X X X

Unemployed women groups X - X X - - - -

Youth and the unemployed X X X X X - X -

Possibility to influence and make decision on implementation of the Project Ministry of Health and

Components 1 & 2 &3: - X - - - X - X


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Level of Stakeholders’ Involvement

Objectives

Communication methods and tools

Group meetings

Individual/ Internal meetings

MOP’s Website/

social media

Project leaflets

in Arabic

Disclosure of documents at

Municipal/ governorate

level

Emails Local

bulletin boards

Correspondence & official letters

relating to project

Environment - Licensing requirements and procedures, - Assigning dumping site, - Updates on labor regulations, - Working conditions and OHS guidance - TORs - GRM - Tender documents - Project updates and reporting

Local government leaders

X X - X X - - X

Community leaders X X X - X - - -

CDGs X - - X X - X - labor unions X - - X - X - X Environmental activists - X - - X X X X

CSOs & NGOs - X - - - X - X State entities & MOP - X - - - X - X

Stakeholders who are not affected by the Project development but may have interest in the Project Other ministries (GOI/KRG)

Components 1 & 2 &3: National and local governmental institutions (whom might require that they undertake certain inspections or auditing exercises and/or might require certain updates on the implementation of the Project).

- X - - - X - X

Financing agencies (MIFs) - X - - - X - X


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6.3. Grievance Redress Mechanism (GRM) During the Project implementation, and carrying out associated activities, negative effects on beneficiaries and issues in the field are very likely, but – as explained above – are different in magnitude. The most effective mitigation measure for the identified impacts will be ensuring that project beneficiaries and project-affected people are actively involved. In this regard, there are two main tools through which this can be achieved: (1) raising public awareness and carrying out mandatory public displays; and (2) establishment of a viable Grievance Redress Mechanism (GRM).

Raising public awareness

Information about the grievance handling system described below will be distributed at an early stage of the Project to all Project Affected Persons through regular information channels used by the Project, including initiating meetings at the start of the Project where feasible, public meetings during project implementation, brochures/pamphlets in Arabic Language, posting on notice boards and online where necessary. The process of raising a complaint should be explained by reaching out to the community in all targeted governorates, or by conducting a meeting with community representatives at the local level. It is important that community representatives include women at all times.

The MOP will have the overall responsibility of addressing concerns brought to the attention of the focal points regarding any environmental and/or social impacts resulting from project activities.

As such, MOP will establish a unit in its head office to handle project activity‐related complaints with one to two dedicated focal points. Multiple access points (telephone, complaint box, website, email, text message, etc.) will be provided so that beneficiaries are provided with several methods to voice their complaints/concerns. The contact information of the GRM focal point(s) will be posted in the local language at the local level. The Project Management Team will have the overall responsibility of addressing concerns brought to the attention of the focal points regarding any environmental and/or social impacts resulting from project activities. Complaints received by MOP (or its local directorates) will be registered, tracked, investigated and promptly resolved. Copies of complaints (records) will be kept in the activity files and the progress reports, including the number, type and actions taken.

Establishment of Grievance Redress Mechanism (GRM)

Existing GRM system

Currently MOP receives notes and inquiries from the public through many channels:

− Public relations, media and communication departments

− Landlines and faxes

− Email addresses dedicated for each directorate

− Social media (Facebook page: العراقیةوزارة التخطیط )

− Web page (www.mop.gov.iq)

− Written notes in the field (through MOP’s local directorates)

− Referred notes and inquiries from other local governments

http://www.mop.gov.iq/


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Proposed GRM system

The following section provides typical requirements for establishing a better system to serve for a Project’s GRM.

The proposed GRM for the SFDP aims to resolve issues that could come across implementation promptly, more efficiently, and accurately. The design of the GRM system should provide means for collecting supportive documents and evidences, investigating the problem, and supporting the final decision. More specifically, the proposed GRM should:

− Reduce fraud and forgery;

− Increase trust between citizens and the state;

− Increase transparency in procedures;

− Include complainer in the process as part of the solution; and

− Circumvent issues before they escalate.

Key design features may include:

− Diversifying complaining channels and access points;

− Providing access points on the local level;

− Setting clear procedures, including the use of simplified local language;

− Swiftly responding to complaints; and

− Allowing a two-way communication channel with the Complainant.

Complainants would commonly approach this GRM for many reasons, including those related to incomplete or no service, vague procedures, inappropriate/ unfair treatment by the staff, and harm (environmental and/or social) to individuals or groups as a result of carrying out the Project’s interventions. Users of the system include all people working under this Project, and Project Affected Persons (PAPs), as well as vulnerable groups providing their grievances directly or indirectly through an intermediate.

The complaint/ grievance, once received, should be promptly resolved or otherwise undergo further investigation. Complaints are sorted out according to complexity. Direct responses should be given to simple inquiries by concerned staff members in 3-6 working days as a maximum, and should be documented and archived as per the relevant procedure. While, more comprehensive measures should be applied to complex issues, including field investigation and communicating with higher management for final decisions within a timeframe of 20 working days as a maximum.

Procedure for Simple issues:

The design of this procedure aims to resolve issues that do not require field investigation, swiftly, directly and on the spot where the complainant lodges his/her application. In this case, the Complaints Receiving Officer (Registration Officer) will interact with the complainant directly and instantly, provide necessary explanations, and take actions accordingly. This would also include the Officer delegating part of, or the whole case to his/her assistant(s), in order to ensure a quicker response, and not overloading higher management unnecessarily.


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More specifically, the Registration Officer shall take the following actions upon receiving the complaint:

− Determine the suitability and validity of the complaint and whether it is related to the Project

or any of its elements. If the complaint is not related to the Project, but is related to another

government entity, the responsible Officer will refer the complainant to the appropriate

authority to process his/her complaint;

− If the complaint is validated, the Registration Officer shall use a pre-prepared application

form to register the issue; and

− The Registration Officer shall then determine whether the complaint is valid for the solution

directly or need to be investigated and raised to a higher level. If the problem needs to be

investigated more, the Registration Officer must submit it directly to the other responsible

officer and not declare any action to the complainant before the investigation is completed.

However, the Officer shall ensure the following points before processing the application:

− Obtain a clear and complete picture of the complaint, this may require asking the complainant

additional questions; and

− Gain enough understanding of the outcome expected by the complainant, if the expectation

was unrealistic or not related to the issue, the Officer shall explain this to the complainant;

This type of complaint shall be resolved in no more than 3 – 6 days, which means that the Complainant must get the final answer within a maximum period of 6 days. The complainant shall also be notified in case of extension and be informed about the reason thereabout. Nevertheless, the duration should not exceed a 10-day time limit including necessary proceedings.

Procedure for Complex issues:

This stage of grievance redress involves further investigation and should be considered for the following cases:

− If Registration Officer has already tried to solve the problem directly, but no satisfactory

result was obtained for the Complainant;

− The Complainant directly requested an investigation;

− The issue already requires careful research and investigation; and

− The problem is serious or could result in broader effects.

However, the following points should be fulfilled before advancing to a higher level:

− The Officer is fully aware of the problem and adequately understands the outcome the

Complainant is looking for;

− The Complainant was contacted for additional information, as there was ambiguity, or

missing supportive documents;


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− The Registration Officer provides all his/her observations and steps taken in the previous

stages to the Officer responsible for the investigation.

The duration of this type of complaints is 20 days as a maximum, meaning the complainant must be notified of the decision and the action taken within a total period of 20 days. In the case of logical and legitimate reasons for extending the duration, the Project Management should determine the time period. The Complainant should be informed of this extension. The reasons for the extension may include:

− The persons involved in the investigation are travelling or on leave;

− Some basic information for the investigation can be obtained only during a certain time such

as the need to obtain administrative approvals; and

− In case of external circumstances, such as the investigation was blocked for security reasons.

There might be other reasons for an extension not listed above. It is the responsibility of the Project Management to assess circumstances and the validity of extending GR time periods.

Closing the Complaint

After the completion of the proceedings, the complaint is closed, and the complaint information is included in the system, including the action(s) taken and the result(s) required. The complainant shall be notified of the result and the action immediately and informed of the possibility of objecting to the procedure. Complainants will have the right to appeal their cases at a tribunal should the offered solution/ compensation deemed unsatisfactory.

The Complaint Registration Mechanism

The Officer responsible for receiving complaints will organize the complaint in the form pre-prepared for this purpose (see Annex III for a sample form). The registration form should contain the following fields as a minimum:

− Name of the complainant

− Complainant's address: Physical address and contact information (Telephone number, E-mail,

if available)

− Content of the complaint

− Referral information (for official use): The Officer responsible, and referral information

− Actions taken

Data Analysis and Reporting

The data will be analyzed and matched with the fieldwork. These data will be used to identify the cause of the underlying problem and to take precautionary measures to avoid future occurrence of the problem. The procedure will also be recorded as a future reference for similar cases.

The report will include total number of complaints, actions taken, number of complaints closed and number of complaints ongoing. Reporting should include statistical information on various receiving


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channels/ access points, and the most used ones. This information and alike will be studied for the sake of improving service in the future.

Complaints lodging points and channels

− The Project Management Office in the Ministry Planning – Baghdad;

− Project Offices in all governorates, and subcommittees on the governorate level; and

− Environmental and Social specialists of the Project in each governorate.

The Table below provides available communication channels for GRM of the SFDP

Table 12: Available communication channels for the GRM

Available channel Contact point

Paper format (pre-prepared registration form)

- Responsible Officer at PMO/ MOP, - Responsible Officer of the sub-committees (to be assigned)

in governorates, then to be submitted via e-mail Telephone - Landlines from all national networks

- Other landlines and mobile lines to be specified - Phone calls to be recorded

MOP Official Websites

www.mop.iq.gov www.mop.gov.krd Responsible Officers in collaboration with IT team

Social Media

Facebook page of MOP (وزارة التخطیط العراقیة)

Project’s email

[email protected] [email protected]

GRM – Roles and responsibilities

The following Table shows key roles and responsibilities for running and sustaining a GRM within the SFDP

Table 13: The proposed GRM roles and responsibilities

GRM staff Roles & Responsibilities Project Manager - General supervision of the conduct of investigation and processing procedures

- Referral of complaints to investigation - Approval of results of the investigation and the measures taken

Head of Complaints Team

- Submitting of Complaints to the PMO - Direct supervision of the investigation and registration teams - Reviewing and approval of the results and procedures - Reporting to the higher management

Investigation Officer

- Managing the investigation of the complaint - Coordination with all parties to obtain all necessary information for a complete result - The conduction of an integrated investigation including recommendations for actions - Reporting to the head

Registration Officer

- Complaint registration by paper and electronic formats - Prompt actions to complaints if possible without referral - Communicating with the Complainant throughout the complaining process - Providing final decisions/ answers and collecting feedback after the Complaint has

been addressed

http://www.mop.iq.gov/

http://www.mop.gov.krd/

mailto:[email protected]

mailto:[email protected]


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For resettlement and land/property related grievances, the Project has prepared a Resettlement Policy Framework (RPF) to address these issues more comprehensively.

World Bank Grievance Redress

Communities and individuals who believe that they are adversely affected by a World Bank‐supported project may submit complaints to existing project‐level grievance redress mechanisms or the World Bank’s Grievance Redress Service (GRS). The GRS ensures that complaints received are promptly reviewed in order to address project‐related concerns. Project affected communities and individuals may submit their complaint to the World Bank’s independent Inspection Panel which determines whether harm occurred, or could occur, as a result of WB non‐compliance with its policies and procedures. Complaints may be submitted at any time after concerns have been brought directly to the World Bank's attention, and Bank Management has been given an opportunity to respond. For information on how to submit complaints to the World Bank’s corporate Grievance Redress Service (GRS), please visit http://www.worldbank.org/en/projects‐operations/products‐andservices/grievance‐redress‐service. For information on how to submit complaints to the World Bank Inspection Panel, please visit www.inspectionpanel.org.


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Chapter 7: Environmental and Social Management Framework

7.1. Proposed Environmental and Social Mitigation Measures As explained in Chapter 5, views of the Project Affected Persons (PAPs) were also taken into consideration and consequently have been reflected on the foreseen type and level of impacts.

To ensure the best alleviation of adverse impacts during implementation, an Environmental and Social Management Framework (ESMF) is proposed. This management framework highlights the requirements of managing environmental and social-related impacts; responsible parties for management; requirements, and timeline for implementing mitigation measures in the broader context. However, small projects, once determined, should undergo screening for site-specific impacts, and preparation of relevant environmental impact assessment and focused management and monitoring plans. Safeguard instruments for each sub-project should be prepared and publicly consulted on before commencement.

This Chapter provides a tool for specific sub‐project level instruments that will be required to cover both environmental and social aspects, including sub‐projects site‐specific Environmental and Social Management Plan (ESMPs) and/or checklists (see Annexes IV&V).

It is worth mentioning here that adverse impacts – depending on the degree of risk – are avoided, eliminated, minimized, mitigated, or accepted. Therefore, negative impacts should undergo a second round of ranking throughout Project life time, in order to give more sense to the effectiveness of applying mitigation measures, and whether they need to be updated.

The ESMF is considered a guide to the preparation of tender documents for smaller projects under this SFDP. However, site-specific ESMPs should be ideally developed by contractors and implementing agencies before commencing their project(s). Those parties will then hold the responsibility for integrating the ESMP in their daily work. Additionally, the contractors as well as the Project proponent are also required to monitor environmental and social parameters and ensure the full adherence to the prepared ESMP.

Impacts identified in this ESMF are generic, and intended to provide a guide to the nature of effects that could arise during implementation of the Project, in general, and throughout construction and operation of site-specific civil works, in particular. However, thorough investigations for impacts should be carried out for site-specific ESMPs. The following Table presents a set of mitigation measures in light of impacts identified at this stage of the Project.

Table 14: Proposed environmental and social mitigation measures

E&S Impacts Mitigation

Component 1: Financing Community Sub-projects Health and safety impacts 1 Occupational health

and safety issues - Avoid manual transfer of big quantities of materials and heavy equipment - Implement administrative controls into work processes, including offering

enough time and suitable conditions to rest - Implement good house-keeping practices, and clean debris and spills regularly - Locate electrical cords and ropes in common areas and marked corridors - Train on and use proper scaffolding systems and personal fall arrest systems - Use suitable Personal Protective Equipment (PPE), including helmets, vests,


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gloves, masks, and hard boots where necessary - Check equipment for electrical loos, and apply maintenance only through

specialized persons - Use electricity-specific PPE where needed - Avoid assigning tasks to unskilled workers where special expertise is required - Provide on-the-job training programs to complement any deficiency


- Provide surveillance and active screening, and immunization - Provide treatment on-site or in community health care facilities; - Eliminate unusable impounded water, and apply vector control programs - Erect suitable and adequate warning signage along culvert cleaning and

excavation sites - Collaborate with local communities and responsible authorities to improve

signage and visibility - Avoid uncovered piles of aggregates and other construction materials; - Avoid burning waste in worksites - Avoid or minimize driving through community areas and dangerous routes

during daytime - Alert drivers on local speed limits, and monitor implementation - Minimize traffic by purchasing from the local markets to the extent possible

Environmental impacts 3 Pollution of the

surrounding environment

- Identify available waste collection and treatment programs - Identify opportunities for reducing, reusing, and recycling waste - Put procedures and operational controls for on-site storage - Segregate and pre-treat oil and sediment/grease-containing effluents - Discharge to sanitary network only after confirming compliance - Monitor groundwater quality that could exist close to the working areas to

ensure compliance - Minimize steepness of slopes to reduce runoffs, including providing for

drainage - Re-vegetate if applicable - Modify/ suspend activities during extreme rainfall and high winds


- Ensure full adherence to the zero-discharge criterion - Oblige by legal transportation and dumping of materials in their pre-

designated and approved dumpsites - Stay in contact with the concerned authorities for accidental events - Raise awareness on the importance of natural life

Cultural heritage impacts 5 Possible damage to

objects of historical/ cultural value

- Make workers aware of the significance and legal liabilities - Put simple and clear instructions for workers in response to chance finds - Liaise with responsible authorities - Suspend excavation work and promptly communicate any chance finds to the

responsible authorities

Socio-economic impacts 6 Unfair - Provide adequate level of representation to vulnerable groups in the field


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representation of the underprivileged/ disadvantaged subgroups

through engaging suitable and experienced NGOs and/or CSOs - Ensure views of vulnerable groups are taken into consideration in planning for

work packages - Provide open and effective channels for addressing complaints (GRM)


- Ensure work packages are within highest development priorities - Ensure fair distribution of work packages/ job opportunities within areas of

need - Ensure work packages are adequately consulted on and endorsed by

community/ tribal leaders - Ensure enough levels of security onsite - Provide open and effective channels for addressing complaints (GRM)


- Increase control over labor market, by regular inspections - Put more stringent employment terms and conditions on contractors, and

business owners - Provide open and effective channels for addressing complaints (GRM) - Enforce punishment against violations

9 Labor influx issues - Select working places far enough from populated areas - Regulate working hours, and provide clear instructions on movement around

the area - Laborers should be subjected to health monitoring, including vaccination

where necessary - Consider local participation while planning for different work packages, with

help from relevant NGOs and CSOs




- Assess the poor under existing databases at MOP and MOLSA. - Ensure a proper complaining system and corrective measures in place







- Preparation of Resettlement Action Plan/ Abbreviated Resettlement Action Plan, including compensation plans, according to provisions of OP/BP 4.12





- Keep wages lower than the market rate in order to mostly attract economically


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disadvantaged individuals. - Survey the local economy on a regular basis throughout the project, to ensure

appropriate levels of wages - Consult other implementing agencies for similar businesses (i.e. CfW wage

structures), to reduce disputes between communities of the same territory - Make pay rates/ modalities clear enough to the beneficiaries


- Limit chain supplies to the local market as much as possible - Provide enough promotional information for beneficiaries when they

approach responsible authorities/ directorates - Increase marketing campaigns for local products through available media


- Provide technical advice for business owners/ seekers - Provide enough means for marketing - Enable relaxed and simplified/ facilitated procedures for debtors to pay back

the loan

7.2. Environmental and Social Management and Monitoring As discussed before, SFDP will mostly involve socio-economic impacts, which are related to the way the social support activities are run and communicated to the target communities. The Project Management is required to maintain a diligent and ongoing level of observation, either at the central or at the local levels, where technical teams and E&S specialists would remain in contact with PAPs and would assist in collect their views dedicated communication mechanisms set in place, including the GRM. In general, the PMO of MOP as well as Project Management Teams in all directorates at the local level are held responsible for supervision and M&E. Other sectoral authorities can also be part of monitoring and providing assistance where required, for instance, traffic, archaeological, labor, environmental and health, and security departments. Costs incurred, and other resources, for management and monitoring should have been already allocated in the Project budget. However, the Project design is flexible and may allow for sourcing out some specialized technical assistance for the sake of preserving a good level of implementation and thus, gain sound results on the ground. These might include support in technical and financial areas, such as targeting and selecting, data/ information management systems, field surveys, financial advice, etc.

On another hand, environmental impacts are foreseen moderate to low in magnitude, site-specific, though should be monitored on periodical bases. Environmental elements to be monitored include, inter-alia, particulate matter, noise, water, soil, waste accumulation, oil spillage, and wastewater discharges. In this case, the PMO of the MOP should determine these requirements and needed resources in early stages, and integrate them into contractor’s agreements. The PMO and other directorates in the field, in liaison with other authorities, are also responsible for monitoring and inspection. A site-specific Environmental and Social Management Plan (ESMP) should be prepared by contractors and revisited throughout the contract period. However, sub-projects are only screened to be category B, in order to be contracted. Additional information on screening and required safeguards instruments are discussed in more detail in Chapter 9.


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This ESMF includes Cost estimates for monitoring pollutants and other provisions of needed devices, which are embedded in the Contractors budget. Project Management is required to monitor and evaluate the implementation compliance with safeguards instrument in the field, as part of their M&E responsibility.

Managing and monitoring Occupational Health and Safety aspects of work is of great importance. Contractors are required to adhere to safety requirements and the use of appropriate protection gear by workers. This ESMF provides a general guide on Best Management Practices (BMPs) for most common work environments but tailored to the small-scale civil works included in this Project. These requirements and guides should form an integral part of agreements with contractors and project implementing agencies (see Annex VI). These guides are mainly extracted from the WBG’s Environmental Health and Safety Guidelines of 2008. PMTs, in collaboration with labor directorates, and other concerned officials in the field are also responsible for monitoring compliance at worksites, and the actual implementation of management measures by contractors.

Additional monitoring measures are also considered to support the implementation, monitoring, and compliance with the ESMF, including: (a) annual fiduciary audits/ post‐review of a subset of sub‐projects with respect to design and implementation of site-specific ESMPs and/or checklists; and (b) implementation support missions carried out by the World Bank which would include environmental and social implementation expertise. The following Table provides a Framework E&S management and monitoring.


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Table 15: Environmental and Social Management and Monitoring Framework

# Impacts Mitigation measures Monitoring Responsibilities Requirements Time/ Frequency Cost estimate

Component 1 - Financing Community Sub-projects 1 Occupational

health and safety issues

- Avoid manual transfer of big quantities of materials and heavy equipment

- Implement administrative controls into work processes, including offering enough time and suitable conditions to rest

- Implement good house-keeping practices, and clean debris and spills regularly

- Locate electrical cords and ropes in common areas and marked corridors

- Train on and use proper scaffolding systems and personal fall arrest systems

- Use suitable Personal Protective Equipment (PPE), including helmets, vests, gloves, masks, and hard boots where necessary

- Check equipment for electrical loos, and apply maintenance only through specialized persons

- Use electricity-specific PPE where needed - Avoid assigning tasks to unskilled workers

where special expertise is required - Provide on-the-job training programs to

complement any deficiency

- MOP/PMO/PMT - Local technical teams - Labor and Social

Assistance Departments (LSADs) of MOLSA

- Environmental specialists - Implementing agencies/

contractors

- Field inspection - Field reports - All available

complaining channels

- Throughout Component 1 program

- On daily basis

- 200 USD/ worker for a complete set of PPE

- Other monitoring costs included in the daily operations


- Provide surveillance and active screening, and immunization

- Provide treatment on-site or in community health care facilities;

- Eliminate unusable impounded water, and

- MOP/PMO/PMT - Local technical teams - Environmental specialists - Local authorities: health,

traffic, etc. - Implementing agencies/

- Field reports - Handheld

Measuring devices (air, PM & Noise)

- Incident reports

- Bi-weekly for measurements


- 10 K USD/ measuring devices

- 1000 USD/month/site for


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apply vector control programs - Erect suitable and adequate warning signage

along culvert cleaning, networks, and excavation sites

- Collaborate with local communities and responsible authorities to improve signage and visibility

- Avoid uncovered piles of aggregates and other construction materials;

- Avoid burning waste in worksites - Avoid or minimize driving through

community areas and dangerous routes during daytime

- Alert drivers on local speed limits, and monitor implementation

- Minimize traffic by purchasing from the local markets to the extent possible

contractors/ E&S specialists

onsite - Health care

centers - Speed

monitoring

measurements and reporting

- 1000 USD/month/site for health care

- Others included in operational cost

3 Pollution of the surrounding environment

- Identify available waste collection and treatment programs

- Identify opportunities for reducing, reusing, and recycling waste

- Put procedures and operational controls for on-site storage

- Segregate and pre-treat oil and sediment/grease-containing effluents

- Discharge to sanitary network only after confirming compliance

- Monitor groundwater quality that could exist close to the working areas to ensure compliance

- MOP/PMO/PMT - Local technical teams - Implementing agencies/


- Environmental specialists - Public health inspectors - Engineers from local

authorities/ water and municipal authorities

- Field reports - Site inspection - Handheld

Measuring devices (water quality)

- Incident reports onsite

- Bi-weekly for measurements


- 10 K USD/ measuring devices

- 1000 USD/month/site for measurements and reporting

- Others included in operational cost


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- Minimize steepness of slopes to reduce runoffs, including providing for drainage

- Re-vegetate if applicable - Modify/ suspend activities during extreme

rainfall and high winds


- Ensure full adherence to the zero-discharge criterion

- Oblige by legal transportation and dumping of materials in their pre-designated and approved dumpsites

- Stay in contact with the concerned authorities for accidental events

- Raise awareness on the importance of natural life



- Environmental specialists - Local authorities/ Ministry

of Health and Environment

- Field reports - Site inspection - Incident reports

onsite - Other authorities

procedures

Periodical inspection (monthly)

- Inspection cost included in the component budget

5 Possible damage to objects of historical/ cultural value

- Keep workers aware of the significance and legal liabilities

- Put simple and clear instructions for workers in response to chance finds

- Liaise with responsible authorities (department of antiquities)

- Suspend excavation work and promptly communicate any chance finds to the responsible authorities



- Environmental specialists - Local authorities/

antiquities dept.

- Procedures for chance finds on the site

- Incident reports onsite

- Other authorities’ specific instructions


- Periodical inspection (monthly)

- Inspection cost included in the component budget

- Costs from other authorities are included in their operational cost

6 Unfair representation of the underprivileged/ disadvantaged subgroups

- Provide adequate level of representation to vulnerable groups in the field through engaging suitable and experienced NGOs and/or CSOs

- Ensure views of vulnerable groups are taken

- MOP/PMO/PMT (central & local)

- Local technical teams - Community development

groups (CDGs) - Social specialists

- Field reports - All available

complaining systems

- Promotional programs

Throughout component implementation

- Cost for targeting and selection is included in total component cost

- 10 K USD/


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into consideration in planning for work packages


- Public Relations - GRM officials - M&E specialists

month/ governorate for promotional programs


- Ensure work packages are within highest development priorities

- Ensure fair distribution of work packages/ job opportunities within areas of need

- Ensure work packages are adequately consulted on and endorsed by community/ tribal leaders

- Ensure enough levels of security onsite - Provide open and effective channels for

addressing complaints (GRM)

- MOP/PMO/PMT - Field inspectors - Local technical teams - Community development

groups (CDGs) - NGOs & CSOs - Security authorities - Site guards - M&E specialists

- Field reports - Security reports

from authorities - Surveillance

systems

Ongoing - 600 USD/month for site guard

- Cost of selecting and targeting included in the budget

- Other costs included within operational costs


- Increase control over labor market, by regular inspections

- Put more stringent employment terms and conditions on contractors, and business owners


- Enforce punishment against violations

- MOP/PMO/PMT - Field inspectors - LSADs of MOLSA - Local technical teams

- Promotional media


complaining systems

- Before start of Component 1 program


10 K USD/ month/ governorate for promotional programs

9 Labor influx issues - Select working places far enough from populated areas

- Regulate working hours, and provide clear instructions on movement around the area

- Laborers should be subjected to health monitoring, including vaccination where

- MOP/PMO/PMT - Field inspectors - LSADs of MOLSA - CDGs, NGOS, and CSOs - Local technical teams - Implementing agencies/

contractors

- Field reports - Health records - All available

complaining systems

- Before start of Component 1 program


- Included within the budget of component 1


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necessary - Consider local participation while planning

for different work packages, with help from relevant NGOs and CSOs

- Health centers




- Assess the poor under existing databases at MOP and MOLSA.

- Ensure a proper complaining system and corrective measures in place

- MOP/PMO/PMT - Social workers - Field inspectors - LSADs - Implementing agencies/

contractors - Database specialists - M&E specialists


complaining systems

- IT System/ programming advice

Throughout component implementation

Cost for targeting and selection is included in overall component budget






- Public relations - Local technical teams - Implementing agencies/

contractors - Social specialists - GRM officials


consultation channels

- All available coordination channels

- All available complaining channels

Ongoing - Cost of RAP/ ARAP varies according to sites

- Cost of monitoring is included in operational costs



- Preparation of Resettlement Action Plan/ Abbreviated Resettlement Action Plan,


- Public relations - Social specialists - GRM officials - M&E specialists


consultation channels

- All available coordination

Ongoing - Cost of RAP/ ARAP varies according to sites

- Cost of monitoring is


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including compensation plans, according to provisions of OP/BP 4.12


channels - All available

complaining channels

included in operational costs




- Keep wages lower than the market rate in order to mostly attract economically disadvantaged individuals.

- Survey the local economy on a regular basis throughout the project, to ensure appropriate levels of wages

- Consult other implementing agencies for similar businesses (i.e. CfW wage structures), to reduce disputes between communities of the same territory

- Make pay rates/ modalities clear enough to the beneficiaries

- MOP/PMO/PMT - Field inspectors - Local technical teams - LSADs and other sectoral

authorities - Outsourced consultants

(economists)

- Field surveys and reports

- Coordination/ communication

- Market analysis reports

Ongoing throughout component 2

- Survey cost integrated within daily operational cost

- Economist fee 2,000 USD/month


- Limit chain supplies to the local market as much as possible

- Provide enough promotional information for beneficiaries when they approach responsible authorities/ directorates

- Increase marketing campaigns for local products through available media

- MOP/PMO/PMT - Field inspectors - Local technical teams - Outsourced consultants

(economists) - GRM officials


media channels - All available

coordination channels



- Promotional and marketing costs are included in the budget



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- Market analysis reports


- Provide technical advice for business owners/ seekers

- Provide enough means for marketing - Enable relaxed and simplified/ facilitated

procedures for debtors to pay back the loan

- MOP/PMO/PMT - Field inspectors - Local technical teams - Outsourced consultants

(economists) - GRM officials


media channels - All available

coordination channels


- Financial advice


- Promotional and marketing costs are included in the budget



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7.3. Site Visits and Reporting Requirements During Project implementation, the PMO should put in place a communication and reporting mechanism in order to achieve goals of the Environmental and Social Management Framework. The system should outline frequency of field visits, communication channels, and content of reporting as a minimum. During implementation, the Project proponent is required to monitor all key environmental indicators on the ground as delineated above. It is advisable to jointly conduct site visits to the Project sites by the Project proponent (MOP) and representatives at the governorate level (including from concerned municipalities), as well as the Contractor's E&S specialists. Site visits and reporting may include the following:

1. Conduct one site visit to each Project site prior to start. This site visit will aim to depict any new environmental and/ or social developments on the ground. This will be helpful for understanding site-specific requirements for preparing a sound ESMP. This site visit should result in preparing a site visit report, which would include: date of visit, participants, and specifics of the site visited, photos, names of interviewees, conclusions, and recommendations. The site report will then be submitted and filed at PMO/ MOP. This is also to be shared with the WB team where applicable.

2. Similarly, conduct another one visit to the worksite after civil works have started already (sub-projects of component 1). This visit will aim to ensure that the Contractor/ implementing agencies understand requirements of safeguards instruments for each site, and the importance of compliance thereto. The participants of the visit should make sure the Contractor/ implementing agencies have hired E&S specialists within their team to handle all related monitoring tasks. The visiting team should report this visit to the higher management (PMO/ MOP). Reporting information should include as a minimum: date of visit, participants, specifics of the visit, observations, photos, names of interviewees, and recommendations for improvement.

3. Continuous reporting (weekly) on safeguards implementation by the Contractor's E&S specialist. Reporting should be made to PMO/ MOP and/or MOP’s directorates in the field, for approval and comments. Then reporting back to the Contractor for further actions.

4. Instant reporting in case of emergency, severe accident, or fatalities by the Contractor’s E&S specialist. Reporting should be made through a dedicated direct hotline with national security forces and/or civil defense.

5. Reporting quarterly on safeguards implementation by the Contractor's E&S specialist. Reporting should be made to PMO for approval and comments. Then reporting back to the Contractor for further actions. Finalized quarterly reports should be submitted to the higher management of MOP and the World Bank.

6. Monitoring process has to include consulting/ interviewing PAPs (recommended quarterly) throughout Project implementation. This exercise aims to collect feedback from the surrounding communities on effectiveness of Environmental and Social Safeguards. This measure would be important to ground-truth actual and effectiveness of implementation of social mitigation measures, and the Grievance Redress Mechanism set forth is effective. All feedback/ complaints should be documented in a site visit report and submitted to the Project Management Office (PMO). A full inventory of interviewees should be included in such a report, which could include, amongst others, the following:

− Name, age, profession, educational level, place of residence, contact information,


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− Daily observations by the interviewee on: dust, noise, air quality, traffic, waste releases, workforce interference with daily/ natural life, targeting and selection of potential beneficiaries, cases of communicable diseases, etc.

− Specific complaints and/or concerns about the Project, and

− Photos as applicable. The following Table gives more insight to the proposed visiting and reporting mechanism

Table 16: Monitoring and reporting schedule during implementation/ construction phase

# Type of reporting

Timing Reporting (from whom to whom)

Description

1 Monitoring Project site before start

Once before start of work

From Representatives of field directorates of MOP, Municipalities, and Contractor's E&S specialist To the higher management of MOP/PMO and the WB

This stems from MOP’s responsibility to ensure preparedness of the Project’s different sites to receive the new interventions (environmentally, socially, etc.). This site report is a descriptive one and should contain expert observations and feedback from surrounding people.

2 Monitoring Contractor's obligations towards ESMP

Once upon starting the Project

From Representatives of field directorates of MOP, Municipalities, and Contractor's E&S specialist To the higher management of MOP/PMO Then From field directorates of MOP to the Contractor for action

This stems from MOP field directorates’ responsibility to ensure Contractor's full compliance to ESMP. This visit report is a qualitative and quantitative one on the Contractor's environmental and social provisions (for example. Handheld monitoring devices, spill containment, PPEs, etc.)

3 Monitoring safeguards

On weekly basis

From the Contractor's E&S specialist To the MOP’s supervision teams, Then back to the Contractor for action

This is to ensure full compliance to environmental and social safeguards by the Contractor throughout Project implementation. This report must be technical in heart, which should include figures and trend analyses for key environmental and social parameters.

4 Monitoring safeguards

Quarterly progress reporting

From the Contractor's E&S specialist To the MOP’s supervision teams, To the higher management at MOP/PMO and the WB Then back to the Contractor for action

Aims to engage higher management in monitoring progress, and to ensure their buy-in. This report should include summary information on parameters above limits and how they were rectified, and other issues, challenges, and actions applied.

5 Reporting emergency, accidents, fatalities, etc.

Instant From the Contractor's E&S specialist/ site engineer To the responsible security forces and/or civil defense and/or care centers Then back to the Contractor for corrective and preventive measures

Aims to ensure preparedness and adequate response for different emergencies at different worksites. And to be able to provide medical assistance on-the-spot. This type of reaction should later on be translated into an updated set of corrective and preventative actions for future incidents.

6 Monitoring complaints/concerns of local community

Quarterly from starting implementation

From Representatives of PMO, Municipalities, and Contractor's E&S specialist To the higher management of MOP/PMO, Then back to the Contractor for action

Aims to rectify proceedings of the Project for healthier environmental and social aspects during implementation, in addition to measure local community's satisfaction/ complaints. This reporting could be integrated within the same quarterly report (as in # 4).


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Chapter 8: Institutional Arrangements and Capacity Building

It is quite essential to have a well-defined institutional and implementation mechanism for identifying, appraising, managing and monitoring safeguards at all levels. This Chapter presents all institutional arrangements that are expected to take part in order to maintain the best environmental and social safeguarding process throughout phases of establishment, implementation, monitoring and evaluation.

8.1. Institutional and Implementation Arrangements The Project will be implemented over five years in total, in all eighteen governorates of Iraq. However, during the establishment phase of the SFDP, and until the draft SFD law is enacted (expected within two years), implementation responsibility will lie with MOP (see Figure 6 for MOP’s Organizational Structure).

Phase 1: The First 2 Years of the Project

During this period, overall interim implementation will be guided by the Supreme Committee for Poverty Reduction Strategy (SCPRS). This committee is an existing umbrella body, chaired by the Prime Minister, and is charged with overseeing a number of poverty-related policies and strategies.

As for project management, MOP will establish and maintain, throughout the implementation period, a Project Management Team (PMT), under the direction of qualified management provided with sufficient resources, and staffed with competent technical and other personnel in adequate numbers and with composition, terms of reference and resources satisfactory to the Bank, as set forth in the Project Operation Manual (POM).

During the first 2 years of Project implementation, the Directorate General of Poverty Reduction Strategy at MOP, will assume responsibility at the central level, while several governorate-level offices will assist in the implementation at the local level.

Composition and Responsibilities of the Project Management Team

During the establishment phase, a Project Management Office (PMO) will be formed within the Directorate General of the Poverty Reduction Strategy of MOP to oversee implementation of the SFD at the central level. The PMO will be headed by a Project Manager, and will include:

− A Procurement Specialist, − A Financial Officer, − A Monitoring and Evaluation (M&E) Specialist, − A Communications Specialist, − An Environmental Specialist, − A Social Development Specialist and − An Administrative Assistant.

The PMO will be in charge of all day-to-day planning, coordination, implementation and supervision of environmental/social safeguards specific to community-driven sub-projects, and will coordinate with all relevant agencies, and governorates. The PMO will also be responsible for documentation, procurement of goods contracting, overall fiduciary activities. Monitoring & Evaluation and reporting to the Ministry of Planning and the World Bank on all aspects of project implementation.


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The PMO will also be responsible for preparing and submitting quarterly progress reports providing detailed information on procurement, financial management, and environmental and social issues. In addition, an annual external audit, combining both technical and financial audit components, will be conducted to ensure the appropriate use of funds and to monitor physical progress in the targeted activities. At the local level, the PMT will be managed by a Project Manager, and will include:

− A Procurement Specialist, − A Community Development Specialist, − A M&E Specialist − An Administrative Assistant, − Engineers assigned from local government and sectoral ministries (education, health,

municipalities etc.) based on local community subprojects.

At the local level, it is expected that assigned engineers and development specialists will conduct regular field supervision to ensure compliance of contractors, their workers and practices, reference to site-specific ESMPs prepared in advance. Responsibilities would also include reporting, ensuring sustainability of operations and maintenance, providing guidance to community groups on all technical-related aspects of sub-projects, and M&E. The PMO will also require contractors to hire specialized staff in environment, social development and health and safety to oversee daily field activities and prepare noncompliance reports upon which the PMO will investigate and take actions accordingly.

PMO and PMT staff would eventually be expected to be transferred to the SFD institution once it is fully established. The PMO and PMTs will also rely on consultancy services to complement the existing capacities at the local level. The institutional structure of the SFD, once the draft law is enacted, is illustrated in the Figure below

Figure 5: SFD Governance and Institutional Arrangements

support

from

support

from

Chaired by the Prime Minister • Composed of select sector ministers, KRG representative, the

High Commission for Coordination between Provinces, private sector, CSOs, experts

• Approve the strategies and policies of the SFD • Approve annual budget and work program • Approve annual and quarterly reports • Authorize entry into agreements with international and local

institutions for purposes of funding and technical assistance • Review and approve external audit reports

Local Technical Team • Composed of local SFD office, local government, local sectoral

ministries • Tasked with ensuring consistency with local development plan

and ensuring sustainability of operations and maintenance

CSOs/NGOs • Facilitation • Mobilizing local communities • Undertaking social and economic assessments on behalf of

SFD and local communities • Support identification of sub-projects

Board of Trustees

Ministry of Planning will manage the SFD during the establishment phase

of 2 years, until the SFD Institution is fully ready

Governorate SFD Offices

Local Communities

Identify needs, priorities, and

Loc

al L

evel

C

entr

al L

evel

Autonomous Social Fund for Development

Central Secretariat


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Phase 2: SFD Establishment

SFD Autonomous Institution

The SFD will be created by law as an autonomous institution, reporting to a Board of Trustees chaired by the Prime Minister. The SFD will have governorate-level offices and a regional office in KRG (KRG SFD Office) with strong human and technical resources to manage SFD at the governorate/local level.

SFD Board of Trustees

The SFD will be governed by a Board of Trustees headed by the Prime Minister, with minister level representation from key sector ministers, KRG representative, the High Commission for Coordination between Provinces, private sector, NGOs, and nationally-recognized experts who are nominated, in addition to the SFD Executive Secretary. The SFD Central Secretariat will be the secretariat of the Board. The Chairman of the Board and the Executive Secretary of the SFD may issue regulations and instructions for the strategic and day-to-day operations of the SFD, as allowed by the law.

SFD Governorate Offices

The SFD will have Governorate Offices to manage the SFD at the local level. The Governorate Office will be headed by a Project Manager. The Governorate Office will manage local-level implementation, supported by a Local Technical Team. It will be responsible for communicating SFD information to local communities, building the capacity of NGOs and community groups, communicating with the SFD Central Secretariat on policy issues, supervising field work, and managing funds

Community Development Groups

With the support of local NGOs and CSOs, SFD will mobilize local communities to elect Community Development Groups (CDGs) representing the different constituents of the community. CDGs will be the intermediary between the local community and the SFD Governorate Office. They will be responsible for consulting with their communities to identify needs, vote for priorities and prepare community action plans for SFD financing. CDGs will support sub-project implementation, ensuring that community contributions are in place as initially agreed. They will also be responsible for informing the local community on the work progress and outcomes, and on the Operations and Maintenance Plans after each sub-project. CDGs will communicate on/work with the community on the resolution of any bottlenecks that emerge during implementation.

NGOs

The SFD Governorate Offices will select NGOs with capacity to act as facilitators with community groups. It will provide orientation and capacity building to these NGOs who are expected to play a key role in community mobilization (i.e. election of CDGs). NGOs will support the SFD in undertaking social and economic assessments and will support the local community in identifying top priorities and sub-projects based on the needs assessment. It will also play a role in monitoring implementation.


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8.2. Implementation Functions Monitoring and Evaluation

The Project will have a comprehensive Monitoring and Evaluation (M&E) framework to ensure appropriate follow-up on indicators at all levels (input, outputs, outcomes). The M&E framework will enable the SFD Board and management to monitor implementation progress, identify challenges, and assess impact of the sub projects financed under the SFD. The Results Framework will guide the monitoring of SFD implementation. Achievement of these results would derive from project implementation and other related indicators (such as local capacity development). Monitoring would be carried out by MOP, and eventually by the SFD institution itself, as well as by third parties, particularly for impact evaluations.

Communication

The Project will develop an extensive communications strategy to reach out to beneficiaries and disseminate clear information on the Project’s objectives, targets and operations, and will help MOP develop and implement an effective Grievance Redress Mechanism (GRM).


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Minister of Planning

Executive Management for

Population Policies

Executive Management for

Poverty Reduction Strategy

National Center for Management

development and IT

Central Organization of Standardization

and Quality Control

Standardization Directorate

Quality Control Directorate

Technical & Administrative

Affairs Directorate

Central Organization of Statistics

Technical Affairs Directorate

IT Directorate

Financial & Administrative

Affairs Directorate

Administrative deputy

Legal Directorate

Governmental Contracts

Directorate

Financial & Administrative

Directorate

Technical deputy

Economic & Financial Policies

Directorate

Human Development Directorate

Regional & Local Development Directorate

Sectors Planning Directorate

Governmental Investment Directorate

International Cooperation Directorate

Minister's OfficeGeneral Inspector

Office

Public Relationas & MediaQuality Mgt &

Institutional Development

Figure 6: MOP’s Organizational Structure


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8.3. Capacity Building and Training Needs The Project proponent (MOP) should provide enough training, and capacity building to the teams responsible for monitoring implementation, after mapping real needs prior to Project commencement. Training needs could include topics on: risk management, environmental management systems, environmental and social impact assessment, public outreach, documentation and record keeping, financial management, occupational health and safety measures, etc.

After the WB has approved the ESMF and been effective, it is recommended that the following stakeholders, either central or local, undergo training:

− Project managers; − Community development specialists; − Environmental and social specialists; − Procurement specialists; − Local Technical Teams (LTTs); − M&E specialists; − Public relation/ GRM personnel at MOP and those assigned in target governorates; − Nominated engineers from sectoral ministries; and − Others as foreseen essential throughout Project implementation.

ESMF-related trainings will be customized to the roles and responsibilities of the various stakeholders, which may include the following areas:

− ESIA requirements and preparation/ sub-project screening/ disclosure − Overview of the ESMF structure, including positive list of subprojects − Mitigation and Monitoring measures, implementation and reporting − Targeting and selection of beneficiaries, record keeping − Public consultation, design, and operation of complaining systems − Best Management Practices onsite, environmental, social, and occupational − Procurement of services and goods

In addition, engineers/E&S specialists in the field should receive customized training (according to their assigned sub-projects), in order to minimize risk of incidents and ensure compliance with ESMF/ESMP provisions. Relevant training topics in this regard would include:

− Introduction to important measures of Occupational Health and Safety − First aid & emergency response − Training on sub-project ESMP preparation, implementation, and reporting

The following Table would provide examples on training workshops/sessions at the MOP’s level, and anticipated costs.


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Table 17: Proposed training workshops and courses Proposed training

sessions Description Target trainees Training

provider(s) Cost estimate

(USD)

ESIA requirements and preparation/ sub-project screening/ disclosure

- Screening sub-projects - National requirements for

environmental permits and procedures

- WB assessment requirements (OP/BP 4.01)

- ESIA preparation and content (with focus on ESMP)

- Information disclosure requirements and procedures, national/ WB

- Project Managers - Environmental and

Social safeguards specialists of the PMO/MOP

- E&S specialists in target governorates

- External consultants

- Ministry of Health and Environment

10,000/ 3days

Overview of the ESMF structure, including positive list of subprojects

- Rationale, objectives and content of preparing ESMF instrument according to the WB’s requirements

- Framework for E&S assessment and impact rating

- Disclosure of ESMF - Review of sub-projects list

- PMO/ MOP - M&E specialists

External consultants

5,000/ 1day

ESMP-Mitigation and Monitoring measures, implementation and reporting

- How to propose mitigation measures and how to set monitoring requirements, timetable, and resources for ESMP

- Reporting requirements and responsible parties

- PMs - E&S specialists

(central & local) - Local technical teams - Coordinators/

engineers/ inspectors in the field

- M&E specialists


- MOP + MOLSA

10,000/ 1day/ governorate

Targeting and selection techniques, record keeping

- Analyze available systems - Showcase from other

similar projects - Essential requirements of an

effective and comprehensive targeting and selection system

- Record keeping, soft and hard requirements

- MOP (central & local) + MOLSA

- CDGs - Local technical teams - M&E specialists


- Guest trainers from other similar projects

15,000/ 1day/ governorate

Public consultation, design, and operation of complaining systems

- Consultation requirements, at national and WB’s levels.

- Identification of project stakeholders

- Hot topics for consultation - Design of consultations,

feedback collection, and follow-up mechanisms

- Key elements for an effective and comprehensive complaining system/ GRM

- PM’s - E&S specialists

(central & local) - Public Relations &

GRM/ Communication specialists

- CDGs - Community leaders/

representatives - CSOs/ NGOs - Contractors/

implementing agencies

- Coordinators/ engineers/ inspectors in the field

- Local technical teams - M&E specialists

- External consultant

- MOP + MOLSA

20,000/ 2days/ governorate

Best Management Practices in worksites, environmental, social, and occupational

- OHS requirements, national & IFC

- Physical, biological, and social aspects and management considerations

- E&S specialists (central & local)

- CDGs - Contractors/

implementing


- MOP + MOLSA



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Proposed training sessions

Description Target trainees Training provider(s)

Cost estimate (USD)

agencies - Coordinators/

engineers/ inspectors in the field

- Local technical teams Procurement of services and goods

- Tendering, proposal evaluation, contracting, managing contractors, payments, liabilities, etc.

- National, and WB instructions in this regard

- MOP/ PMO - Procurement

specialists (central & local)

- Administrative assistants

- M&E specialist



Sub Total (USD) 95,000/ workshop

Logistics, communication, and follow-up 50,000

Total (USD) 145,000

Upon accomplishment of the new interventions (civil works of the Component 1), inspectors and coordinators in the field should have the full capacity and knowledge on the residual impacts onsite. Those officials have to be familiar with the contract's provisions and penalties, should the obligations toward restoring original working environments unfulfilled.

As negative impacts on sensitive receptors in the surrounding environment (physical and biological) may arise in the longer run, special training for monitoring levels of pollutants (air, noise, vibration, land/soil, water, and wastewater) might be required. These may include using, calibrating, and performing light maintenance for monitoring devices (portable/handheld, and stationery) in the field. Training should also include sampling and sample storage techniques against internationally endorsed testing and sampling procedures (examples include WHO and USGS methods, as well as Standard Methods for the Examination of Water and Wastewater by APHA, AWWA, WEF).


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Chapter 9: Screening and Safeguards Instrument

9.1. Sub-Project E&S Screening and Approval Framework The Project has been screened as category B (according to OP/BP 4.01) as it will include limited scale, and site-specific packages of civil work activities. However, the Project – through its Component 1 – will include short-term employment activities through selective community-driven development initiatives. In particular, these initiatives will include labor intensive works like: rehabilitation and maintenance of irrigation canals, local roads, schools, health centers, public buildings, access to markets, and other essential services. As these are small-scale projects, impacts are expected to be minor, site‐specific, limited, reversible, and can be mitigated by contractors/ implementing agencies. This section presents a framework methodology for the screening, categorizing, reviewing, approving, safeguarding, and monitoring of sub-projects. Sub-projects are screened for potential Environmental and Social impacts using the screening checklists included as Annex IV. Before commencing any of the sub-projects designed in this Project, this screening tool should be followed, in order to determine suitable level of safeguard instruments to be prepared. No detailed/full ESIA is expected to be required, as activities are most probably screened as Category B. Nevertheless, No category A‐type sub-projects are allowed within this SFDP, and No sub-projects that would trigger any safeguard policy not triggered under the project are allowed as well. The following are the proposed screening tools:

− Monitoring ESMP Checklist: for sub-projects resulting in relatively low-significance environmental and social impacts. The checklist represents the minimum E&S requirements during the implementation phase. Estimated cost: 5,000 USD

− Site-specific ESMP: for sub-projects resulting in relatively medium-significance environmental and social impacts. Estimated cost: 20,000 USD

− Site-specific ESIA: for sub-projects resulting in relatively high-significance environmental and social impacts. Estimated cost: 30,000 USD

− ARAP/RAP: for sub-projects and activities resulting in temporary and/or permanent resettlement and land taking activities, either voluntarily or involuntarily (although very unlikely). Estimated cost: 30,000 USD

The Bank will then review the screening results and accordingly the safeguards relevant instruments shall be confirmed, prepared, consulted with stakeholders and disclosed. Following clearance of the safeguards instruments by the Bank and/or GOI, the ESMPs shall be implemented, supervised and monitored. The Figure below outlines the proposed methodology.


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Figure 7: Outline of the E&S Screening and Approval Methodology

Potential sub-projects of Component 1 as explained in the PAD will include small-scale civil work interventions, in both urban and rural areas. The community sub-projects program is worth 262 million USD in total, which will be downscaled to all 18 governorates over 5 years. Interventions will be sub-contracted with local venders with the close support from experienced NGOs and CSOs, who will help local communities to voice their urgent needs. However, to the date of preparing this ESMF, individual contract prices are not known. As a reminder, small-scale sub-projects will include, amongst others, the following.

Table 18: Potential sub-projects as presented in PAD

Sub-projects of the community-driven sub-projects • Maintenance of agricultural roads • Maintenance of irrigation canals • Maintenance of local roads • Rehabilitation and repair of schools and educational centers (with possible

minor expansions) • Rehabilitation and repair of health centers (with possible minor expansions) • Rehabilitation and repair of public service buildings • Restoration of public services • Repair or minor localized expansion of small-scale municipal infrastructure • Repair of small water networks • Access to markets • Other similar activities

In general, the screening checklists in Annex IV shall be used as mentioned to determine the appropriate safeguard instruments. However, as a general guide, the following Table provides proposed safeguard instruments based on experience.

Implementation of agreed actions; accompanied by supervision and monitoring & evaluation

Review and clearance of the safeguard instruments within the GOI and/or by the WB

Preparation of safeguards instruments, consultation, and disclosure - if needed

Review of safeguards screening by WB

Screening for potential E&S impacts and safeguard instrument selection according to WB guidelines


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Table 19: Safeguard instruments proposed for the sub-projects identified to date

Sub-project Selected Safeguard Instrument

Justification

- Light maintenance of agricultural roads

- Light maintenance of irrigation canals

- Light maintenance of local roads

- General clearance of areas (or for any other purpose that would serve a community or public need)

Checklist ESMPs All work involving quick maintenance and clearing of lands/ roads are considered light and would result in minor impacts on workers (tiredness, falling), dust. Therefore, preparing checklist ESMP is adequate at this stage

- Rehabilitation and repair of public service buildings

- Restoration of public services

- Repair or minor localized expansion of small-scale municipal infrastructure

- Repair of small water networks

Site-specific ESMPs - Use of paint and solvents would result in some medium impacts on physical environment and biota in the immediate surroundings as well as some health issues on workers

- Painting rising walls and buildings will need scaffolding that may result in moderate impacts on workers in case of accident

- Working on culverts/ drainage and/or water networks along streets will need management plans, especially those related to traffic and road safety. Therefore, a fully-fledged ESMP has to be prepared per working zone.

- Rehabilitation and repair of schools and educational centers (with possible minor expansions)

- Rehabilitation and repair of health centers (with possible minor expansions)

Site-specific ESIAs (see Annex V for basic content of ESIA report)

Rehabilitation could involve comparably heavier civil works. More impacts are expected. However, subprojects classified as category A will disqualify, and should not be initiated.

- Site clearance that would involve relocation of squatters

- Maintenance of public buildings that are potentially used as shelters for IDPs

- Access to markets that would affect access to resources

ARAP or RAP according to numbers of PAPs (See Annex IV & RPF report)

These activities will results in involuntary resettlement or loss of assets or access to resources. Field surveys should be done in this case to determine loses, and resettlement action plans for relocation should be initiated. Such plans should necessarily include complaining, consultation, and compensation (all in line with OP/BP 4.12).


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The sub-project safeguarding, approval and disclosure methodology is shown below in the following Table.

Table 20: Safeguarding, approval and disclosure methodology

# Step Scope Criteria Outcome 1 Screening for

Potential Environmental and Social Safeguard Impacts and Determination of Safeguards Category for each Sub -project

- Screen proposed sub-project according to safeguards checklist (Annex IV)

- Determine applicable WB requirements

- Determine instruments needed to meet requirements

Checklist ESMP: for sub-projects resulting in relatively low-significance E&S impacts. Site-specific ESMP: for sub-projects resulting in relatively medium-significance E&S impacts. Site-specific ESMPs: for sub-projects resulting in relatively high-significance environmental and social impacts. ARAP/RAP: for sub-projects and activities resulting in temporary and/or permanent resettlement activities.

E&S Assessments and Management & Monitoring instruments

2 Review of Safeguards Screening by the WB

- Prepare subproject-specific Safeguards Screening summary

- Assess Safeguards Screening

- A. Safeguards Screening Summary (SSS)

- Screening Rationale - Safeguard instruments

submitted as part of sub-project identification package

- B. Selective review of SSS

- Safeguards Screening Summary (SSS)

- Approval/Revision of SSS

3 Preparation of Safeguards Instruments, Consultation and Disclosure

- Draft E&S instruments

- Consult on draft E&S instruments

- Incorporate feedback in final E&S instruments

- Draft E&S instruments according to WB requirements

- Liaise with WB in case clarifications or changes arise

- Include project stakeholders, project-affected groups, local NGOs in consultations

- Initiate consultations as early as possible

- Provide relevant material in Arabic, comprehensible and accessible formats

- Ensure enough time is provided to examine documents ahead of consultation events

- Document stakeholder feedback and ensure disclosure & meaningful consultation

- Show how stakeholder feedback was addressed in final E&S instrument

- Draft E&S instruments

- Consultation on draft E&S instruments

- Final E&S instruments

4 Review and Clearance of Safeguard Instruments

Review and clearance of E&S instruments

- Review according to WB requirements

Cleared E&S instrument according to WB requirements

5 Implementation of Agreed Actions and

A. E&S safeguards implementation

A. Sub-project proponent contractually obliged to

A. E&S instrument


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# Step Scope Criteria Outcome Supervision, Monitoring and Evaluation (M&E)

B. Safeguard implementation supervision C. M&E

implement E&S safeguards B. WB team may conduct regular visits to supervise implementation of safeguards instruments and compliance with the Bank policy requirements. C. Independent consultants carry out monitoring programs as a third party

implementation B. E&S instrument implementation review C. E&S instrument implementation, M&E, and improvements

9.2. Cost Estimates The Table below includes a preliminary cost estimate for the implementation of the site-specific ESMP/ESIA

Table 21: Cost estimates for E&S safeguards instruments (per sub-project)

Activity Unit Unit Rate (USD) 1. ESIA/ESMP preparation Study/Report

ESMP ESIA ARAP RAP

15,000 20,000 10,000 15,000

2. Personnel (management & monitoring) Man Month (MM)

2,000

PMO/ Central Level

- Environmental & Social safeguards specialist

Local Level

- Environmental and social workers/ researchers

MM MM

3,000 3,000

3. Training and awareness - 30,000

- Contingencies (approx. 10% of total costs)

- Approx. 10,000


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References

− Al-Shauk, S. L. “Evaluation of Noise Levels in Al-Najaf Al-Sharaf Streets, Iraq”, 2014. http://www.iaeme.com/MasterAdmin/UploadFolder/EVALUATION%20OF%20NOISE%20LEVELS%20IN%20AL%20NAJAF%20AL%20ASHRAF%20STREETS%20IRAQ/EVALUATION%20OF%20NOISE%20LEVELS%20IN%20AL%20NAJAF%20AL%20ASHRAF%20STREETS%20IRAQ.pdf

− Ceicdata, “Iraq IQ: PM2.5 Air Pollution: Mean Annual Exposure: Micrograms per Cubic Meter,” https://www.ceicdata.com/en/iraq/environment-pollution/iq-pm25-air-pollution-mean-annual-exposure-micrograms-per-cubic-meter

− Central Statistical Organization, “Iraq population and other indicators,” http://www.cosit.gov.iq/ar/2013-01-31-08-43-38

− Constitution of Iraq, http://www.washingtonpost.com/wp-dyn/content/article/2005/10/12/AR2005101201450.html?noredirect=on

− Fanack, 2016. “Water Quality in Iraq”. https://water.fanack.com/iraq/water-quality-in-iraq/#_ftnref5

− Hatem K. al-Jiburi and Naseer H. al-Basrawi, 2013. ‘Hydrogeological Map of Iraq, Scale 1: 1000 000’, 2nd ed. Iraq Bulletin of Geology and Mining, Papers of the Scientific Geological Conference, vol. 11, no. 1, 2015, pp. 17-26.

− Jaleel. Z. "The Effect of Road Traffic Noise at Hospitals in Baghdad". Journal of Engineering and Development, vol. 18, No. 3, May 2014, ISSN 1813 – 7822

− Khanjer E., Yosif M., Sultan M., "Air Quality Over Baghdad City Using Ground and Aircraft Measurements". Iraqi Journal of Science, 2015, vol 56, no.1C, pp: 893-845

− Mercy Corps, “Guide to Cash for Work Programming,” 2007. https://www.mercycorps.org/files/file1179375619.pdf

− Ministry of Environment, “Iraqi Fourth National Report to the Convention to Biological Diversity,” 2010. https://www.cbd.int/doc/world/iq/iq-nr-04-en.pdf

− Ministry of Planning /KRG, “Weather statistics in Kurdistan Region s governorates – 2012-2018”, http://krso.net/files/articles/290718044457.pdf

− Ministry of Planning, “National Development Plan 2018 – 2022,”Iraq. http://www.iraq-jccme.jp/pdf/archives/nationaldevelopmentplan2018_2022.pdf

− Ministry of Planning. “Framework for Development and Reconstruction in Governorates after Terrorism”, 2017.https://mop.gov.iq/static/uploads/6/pdf/15081505360c5d0bcaf79487c715e493df66abb7bc--

االعمار20اعادة%20وثیقة% .pdf

− Nature Iraq. “Environmental Legislation Guides in Kurdistan Region – Iraq”, 2015. http://www.natureiraq.org/uploads/5/2/9/9/52997379/english.pdf

− UN-ESCWA – BGR. Shared tributaries of the Tigris River. Beirut, 2013. http://waterinventory.org/surface_water/shared-tributaries-tigris-river

− Weather Online, “Weather in Iraq,” https://www.weatheronline.co.uk/reports/climate/Iraq.htm

− WHO. "Guidelines for Drinking-water Quality". 1st Addendum to 3rd edition. Vol.1, 2006. http://www.who.int/water_sanitation_health/dwq/gdwq0506.pdf

− Wikipedia, “Geography of Iraq”, https://en.wikipedia.org/wiki/Geography_of_Iraq#Climate

http://www.iaeme.com/MasterAdmin/UploadFolder/EVALUATION%20OF%20NOISE%20LEVELS%20IN%20AL%20NAJAF%20AL%20ASHRAF%20STREETS%20IRAQ/EVALUATION%20OF%20NOISE%20LEVELS%20IN%20AL%20NAJAF%20AL%20ASHRAF%20STREETS%20IRAQ.pdf



https://www.ceicdata.com/en/iraq/environment-pollution/iq-pm25-air-pollution-mean-annual-exposure-micrograms-per-cubic-meter

https://www.ceicdata.com/en/iraq/environment-pollution/iq-pm25-air-pollution-mean-annual-exposure-micrograms-per-cubic-meter

http://www.cosit.gov.iq/ar/2013-01-31-08-43-38

http://www.cosit.gov.iq/ar/2013-01-31-08-43-38

http://www.washingtonpost.com/wp-dyn/content/article/2005/10/12/AR2005101201450.html?noredirect=on

http://www.washingtonpost.com/wp-dyn/content/article/2005/10/12/AR2005101201450.html?noredirect=on

https://water.fanack.com/iraq/water-quality-in-iraq/#_ftnref5

https://www.mercycorps.org/files/file1179375619.pdf

https://www.cbd.int/doc/world/iq/iq-nr-04-en.pdf

http://krso.net/files/articles/290718044457.pdf

http://www.iraq-jccme.jp/pdf/archives/nationaldevelopmentplan2018_2022.pdf

http://www.iraq-jccme.jp/pdf/archives/nationaldevelopmentplan2018_2022.pdf

https://mop.gov.iq/static/uploads/6/pdf/15081505360c5d0bcaf79487c715e493df66abb7bc--%D9%88%D8%AB%D9%8A%D9%82%D8%A9%20%D8%A7%D8%B9%D8%A7%D8%AF%D8%A9%20%D8%A7%D9%84%D8%A7%D8%B9%D9%85%D8%A7%D8%B1.pdf

https://mop.gov.iq/static/uploads/6/pdf/15081505360c5d0bcaf79487c715e493df66abb7bc--%D9%88%D8%AB%D9%8A%D9%82%D8%A9%20%D8%A7%D8%B9%D8%A7%D8%AF%D8%A9%20%D8%A7%D9%84%D8%A7%D8%B9%D9%85%D8%A7%D8%B1.pdf

http://www.natureiraq.org/uploads/5/2/9/9/52997379/english.pdf

http://waterinventory.org/surface_water/shared-tributaries-tigris-river

https://www.weatheronline.co.uk/reports/climate/Iraq.htm

http://www.who.int/water_sanitation_health/dwq/gdwq0506.pdf

https://en.wikipedia.org/wiki/Geography_of_Iraq#Climate


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Annexes

Annex I: Pollutants’ Thresholds A. Maximum allowable limits for air pollutants (stationary sources) by different regulators

Pollutant

Government of Iraq KRG World Health Organization (WHO) – 2006

Maximum permissible

concentration Remarks

Maximum permissible

concentration Limit Monitoring period

(averaging time) Remarks

Sulfur Dioxide (SO2)

500 mg/m3 -

- 500 μg/m3 10 min

Mean value

- - 1 hr

0.14 ppm (primary) 20 μg/m3 24 hr

0.030 ppm (primary) - 1 yr

Carbon Monoxide (CO)

250 mg/m3 other than fuel combustion sources

- 100 μg/m3 15 min

Mean value

500 mg/m3

from old combustors - 60

μg/m3 30 min

250 mg/m3 from new combustors

35 ppm (primary) 30 μg/m3 1 hr

9 ppm (primary) 10 μg/m3 8 hr

Nitrogen Oxides (expressed as NO2)

70 mg/m3

From gaseous fuel combustion - 200

μg/m3 1 hr Mean value 150 mg/m3 From liquid fuel

combustion

- - 24 hr 0.053 ppm (primary & secondary)

40 μg/m3 1 yr

Ozone 250 mg/m3 - 0.075 ppm (primary & secondary)

100 μg/m3 8 hr Mean

value

TSP 250 mg/m3 From fuel combustion sources

- - - -

PM2.5 - -

35 mg/m3 (primary & secondary)


value 15 mg/m3 (primary & secondary)

10 μg/m3 1 yr

PM10 - -

150 mg/m3 (primary & secondary)


value - 20 μg/m3 1 yr

Volatile Organic Compounds (VOCs)

20 mg/m3 All sources - - - -

Source: National Air Emissions Standards, instructions no. 4 – 2012, and KRG Ambient Air Quality instructions no. 2 – 2011


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B. Discharge consent parameters

Pollutant Limits for discharge to water resources Limits for

discharge to public sewers

Color - - Temperature Less than 35°C 45°C Suspended solids 60 750 pH 6 – 9.5 6 – 9.5 Dissolved Oxygen (DO) - - Biochemical Oxygen Demand (BOD) Less than 40 1,000

Chemical Oxygen Demand (COD) Less than 100 -

Cyanide (CN-) 0.05 0.5 Fluoride (F-) 5.0 10 Free Chlorine (Cl2) Traces 100

Chloride (Cl-)

A. If the ratio of the amount of water discharged to the amount of source water is 1000:1 or less, the chloride concentration of the discharge is permitted at 1% of the concentration of the natural source before discharge.

B. If the ratio of the amount of water discharged to the amount of source water is more than 1000:1 the wastewater discharge must not exceed a chloride concentration of greater than 600 mg/L.

C. If the concentration of chloride in the source water is less than 200 mg/L then the permitted discharge limit must be established on a case by case basis

600

Phenol 0.01 – 0.05 5 – 10

Sulfate (SO42-)

A. If the ratio of the amount of water discharged to the amount of source water is 1000:1 or less, the sulfate concentration of the discharge is permitted at 1% of the concentration of the natural source before discharge.

B. If the ratio of the amount of water discharged to the amount of source water is more than 1000:1 the wastewater discharge must not exceed a sulfate concentration of greater than 400 mg/L.

C. If the concentration of sulfate in the source water is less than 200 mg/L then the permitted discharge limit must be established on a case by case basis

300

Nitrate (NO3-) 50 -

Phosphate (PO43-) 3 -

Ammonium (NH4+) - -

DDT Nil - Lead (Pb) 0.1 0.1 Arsenic (As) 0.05 0.05 Cupper (Cu) 0.2 - Nickel (Ni) 0.2 0.1 Selenium (Se) 0.05 - Mercury (Hg) 0.005 0.001 Cadmium 0.01 0.1 Zinc (Zn) 2.0 0.1 Chromium (Cr) 0.1 0.1 Aluminum (Al) 5.0 20 Barium (Ba) 4.0 0.1 Boron (B) 1.0 1.0


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Pollutant Limits for discharge to water resources Limits for

discharge to public sewers

Cobalt (Co) 0.5 0.5 Iron (Fe) 2.0 15 Manganese (Mn) 0.5 - Silver (Ag) 0.05 0.1

Total Hydrocarbons & Derivatives

Allows discharge of total hydrocarbons to water sources and A1 and A2 according to the concentrations and limitations set forth in the tables below; the concentration of hydrocarbons must be measured discharging to the water source. Hydrocarbons shall not be discharged to water sources A3 and A4. For rivers in continuous flow 10 mg/l according to the ratio of the amount of wastewater discharged to the amount of the water source should not be less than 1000:1. For a river in a continuous flow 3 mg/L and in accordance with the ratio of the amount of the wastewater discharged to the amount of water source should not be 300:1 or less.

-

Sulfide (S2-) Nil 3.0 Ammonia (NH3) Nil 10 Ammonia gas (free NH3) Nil 6.0 Sulfur dioxide SO2 Nil 7.0 Calcium Carbide CaC Nil Not allowed Organic solvents Nil Not allowed Benzene Nil 0.5 Chlorobenzene Nil 0.1 TNT Nil 0.5 Bromine (Br2) Nil 1 – 3


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Annex II: Public Consultation Questionnaire & Participants’ List a. English version

Republic of Iraq – Ministry of Planning Iraq “Social Fund for Development” Project

Stakeholders’ Consultation Questionnaire

Introduction

The Government of Iraq (GOI) has received financial support from the World Bank for the Iraq Social Fund for Development Project (SFDP). This is a 5-year project and will be operated and implemented by the Ministry of Planning (MOP). The Project activities will extend to three governorates in the first year of the Project: Muthanna, Salahiddin and Dohuk. And then the inclusion of four other governorates in the second year, namely: Ninawa, Baghdad, Dhiqar, and Qadissiyah. And then expand to the rest of Iraq's governorates (18 in total) by the last year of the project. The main development objectives of the Project are: (1) Improve access to basic services and; (2) Increase short-term employment opportunities, in targeted communities, including women. The Project consists of the following main components:


The objective of this component is to improve access of communities to basic services. It will finance subprojects at the local level, which consist of basic essential services that represent priority investments identified by the community, with help from NGOs. These will be based on a menu that includes investments that can be realized using labor-intensive techniques and maximizing the use of local materials. The work will start with Muthanna, Salahdieen, and Dohuk during the first year, and expand to Ninawa, Baghdad, Thiqar, and Qadisiya, during the second year, and subsequently to all 18 governorates by year five. The component will finance community level subprojects in education, health, water, small-scale economic infrastructure, and access to markets.

Component 2 – Supporting Microfinance Systems

The objective of this component is to support the establishment of the overall MSE program of SFD through technical assistance and capacity building activities. Support will be provided to the Government of Iraq on: (1) enhancing capacity to manage MFIs that will be engaged under the SFD in the future; (2) reviewing the regulatory environment to allow MFIs to function without market distortions; and (3) developing a framework for structured financing that would allow the flow of funds from SFD to MFIs in a sustainable manner, while meeting SFD objectives



Positive impacts of the Project include:

- Investments in agricultural infrastructure will boost agricultural productivity of local farms - Improvement in the farming and ancillary roads will increase market accessibility to farm products, generating higher

income for farmers - Improvements in road connectivity will also lead to a higher volume of goods and services traded between the Project

communities and the outside economy, leading to an overall rise in job opportunities and welfare levels - Fostering participation of the poor and marginalized citizens (including women) in decision-making process at the

community level - Providing short-term job opportunities, including for women, people with disabilities, and special needs - Rehabilitation and repair of schools will facilitate enrolment of school-aged children in schools, who have missed

school years due to violence and displacement - Rehabilitation or improvements of health facilities will contribute to efforts to reduce out-of-pocket health expenses by

offering preventative care in local health facilities - Building cohesion and social cooperation and enhancing trust and transparency between citizens and the government. Note: The Project will formulate comprehensive plans to manage, process and control any negative impacts on the community and environment that may arise during the implementation of certain project activities. These plans will be binding on Project owners, contractors and any other implementing parties.


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Republic of Iraq – Ministry of Planning Iraq “Social Fund for Development” Project

Stakeholders’ Consultation Questionnaire Name:

Gender:

Age:

Profession:

Marital status:

Education:

Address: Date:

I. Expected Negative Environmental and Social Impacts – Please rate the following impacts

Impacts Rating

I strongly agree I agree I doubt

it I disagree

Component 1 – Financing Community Sub-projects 1 This part of the Project will provide many opportunities to rehabilitate basic

service facilities and create jobs for the people through small-scale civil works, but do you think workers will be exposed during their work to: stress, slippage, falls from heights, injuries, electric shocks, respiratory problems, and others?

2 The Project will improve the quality of the basic services and infrastructure for the local community, including cleaning and maintenance of drainage channels along the roads, in addition to cleaning and rehabilitating irrigation channels and the agricultural and ancillary roads, but do you think the community will be exposed to dust and noise, traffic congestions, or spreading of diseases as a result of these activities?

3 The contractor, who will carry out the maintenance and civil works, will be charged with a site-specific Environmental and Social Management Plan to preserve the work environment and the surrounding physical and biological environment, reduce pollutants and monitor their levels, including: gaseous and dust emissions, noise, wastewater disposal, solid waste accumulation, oil spillage and soil/water pollution. Do you expect these actions to be adequate and effective?

4 Strict terms and conditions will be imposed on contractors during their implementation of small-scale civil works, concerning interfering with the surrounding environment. However, biological life (animals, birds, plants, and riparian species) could still be impacted. What do you think?

5 It will be stressed and made liable for the contractors and workers from the local community to avoid damage/vandalism to historical, archaeological sites, monuments, chance finds, looting of antiquities, consequences of noncompliance, and the need to report instantly. Do you think these measures would be enough?

6 Community organizations, who will represent the voice of various segments of the community, including marginalized and vulnerable groups (the poor, women, the elderly, the disabled, and people with special needs), will ensure their participation in the selection and planning of subproject activities and their fair and adequate representation, What do you think?

7 It is expected that strict terms and conditions will be established with contractors for the small-scale civil works, in addition to diligently supervising work onsite. This will ensure the quality of the work, punctuality, provision of all necessary materials, fair distribution of rehabilitation works among the affected communities, and increased level of communication, as well as consultation with members of the community. Are you satisfied with these measures?

8 The Iraqi laws clearly stipulate rights of workers, including rights for fair remuneration, and provision of appropriate working conditions, as well as prohibition of forced labor and child labor. Do you expect these problems to


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Impacts Rating

I strongly agree I agree I doubt

it I disagree

arise despite the existence of laws and penalties?

9 This Project is mainly aiming at providing jobs for members of local communities affected by recent conflicts. Therefore, local people will be hired, in addition to providing working areas as far away from the residential areas as possible. Nevertheless, do you expect non-locals to take jobs in the Project, transmit diseases, or cause nuisance to hosting communities in nearby places?

10 One of the Project’s key objectives is to provide job opportunities to members of affected communities based on fair selection of beneficiaries and social justice, regardless of ethnicity, religion, culture, physical fitness, gender, and age. What do you think?

11 The Project does not include taking of land or private property. But limited areas might be needed for work preparation and storage of materials, which will be mainly sought from state-owned properties. Although very unlikely, do you expect that this will result in: (1) relocation of encroachers/squatters; (2) loss of income or means of livelihood; and/or (3) loss of assets or access to assets, and interruption of daily life?

12 Iraqi laws and World Bank’s regulations stress that Project Affected Persons are entitled to receive fair and adequate compensation. What do you think?

Component 2 – Supporting Microfinance Systems 13 The Project will review the regulatory environment to allow MFIs to operate in

the market without causing inflation and price distortion in local markets. What do you think?

14 The microfinance system within this Project will put in place the proper environment to ensure the availability and smooth flow of supplies for business owners in their locations, and will also help create an appropriate commercial and marketing environment to encourage demand for local products and services. What do you think?

15 The Project will provide soft loans and fiduciary support that will increase the income of the beneficiary families and facilitate paying back the loan. What do you think?

II. Do you have any other expected Social and Environmental Impacts? Impacts Rating

Significant Moderate Minor Component 1 - Financing Community Sub-projects

1

2

3

Component 2 - Supporting Microfinance Systems

4

5

6

III. General Comments on the Project

---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------


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Annex IV: Environmental & Social Screening Criteria/Checklists

Objective

To determine the WB safeguard instruments for each sub-project

In order to achieve the above, the screening process follows two stages:

- Stage 1: Criteria/Checklist 1 – Category A Checklist. The objective of this Checklist is to identify projects which would have highly significant and sensitive E&S impacts (WB OP 4.01 Category A) and exclude them from the project.

- Stage 2: Screen the sub-project against Criteria/Checklist 1– Detailed Impact Assessment Checklist, in order to assess the level of significance of potential E&S impacts, determine the WB safeguard instruments needed (Monitoring ESMP Checklist, Site-specific ESMP, Site-specific ESIA)

- Stage 3: Identify if the sub-project will trigger OP 4.12 and determine the WB instruments needed (RPF and RAP).

Stage 1: Criteria/Checklist 1 – Category A Checklist (to identify projects with high E&S impacts)

If any of the answers to the questions below was “Yes”, then the sub-project would be classified as WB Category A and should be excluded from the Project.

a. Category A – Checklist Sub-project title: Sub-project brief description: Questions Answer (Yes/No) Will the project: 1. Cause sensitive (direct and or cumulative) impacts? Examples of Sensitive impacts are those, which may be irreversible, or those which raise issues related to natural habitats and/or physical cultural resources.

2. Cause diverse (direct and or cumulative) impacts? Diverse impacts are those impacting different media (air quality, water quality, noise level, and risk to the community) at the same time.

3. Cause unprecedented impacts? Unprecedented impacts are those, which have not been experienced before in the Project’s area of influence (i.e. those which occur for the first time in the area)

4. Have an area of influence that significantly exceeds its footprint? 5. Cause significant residual impacts? Stage 2: Criteria/Checklist 2 - Detailed Impact Assessment Checklist

- If the answer was “Yes” to any of the questions, then a site-specific ESMP or a site-specific ESIA shall be prepared for the sub-project (The site-specific ESIA should be prepared for sub-projects involving multicomponent sites (i.e. rehabilitation of buildings or sites that include various types of work packages; plumbing, plastering, tiling, electrical wiring, painting, gardening, etc.)

- If the answer was “No” to all questions, then the simple monitoring ESMP checklist could be used (move to stage 3).


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b. Site-specific ESMP/ESIA – checklist Question Answer

(Yes/No) Other

categories affected

a. Water (quality and resources)

a1 Is the sub-project adjacent to waterways? a2 Will the sub-project generate solid waste? a3 Will the sub-project generate liquid waste? a4 Will the sub-project generate demolition waste? a5 Will the sub-project generate hazardous waste (grease, oil, empty

paint containers, etc.)?

a6 Will the sub-project consume a considerable amount of potable water (higher than 3m3/site/day)?

a7 Will the project cause interruption to water flows? b. Air (Quality and Noise level)

b1 Will the sub-project make use of chemicals, corrosives, and solvents? b2 Will the sub-project use machinery? b3 Will the sub-project involve refurbishment works (marble, concrete,

ceramics, wood, etc.)?

b4 Will the sub-project activities generate volatile Organic Compounds VOCs (paints, asphalt heating, preparation and application, etc.)?

b5 Will the sub-project involve major and/or minor demolition works? b6 Will the sub-project involve Asbestos management? b7 Will the sub-project involve the installation of air conditioning

elements/systems?

b8 Will the sub-project involve waste burning? b9 Will the sub-project involve generation of odors? c. Soil (quality and erosion)

c1 Will the sub-project cause soil erosion? c2 Will the sub-project cause topsoil loss? c3 Will the sub-project involve soil compaction? c4 Will the sub-project involve concrete foundations/impervious layers? c5 Will the sub-project involve equipment on-site fueling and storage? c6 Will the sub-project involve significant excavations and/or

movement of earth?

d. Social impacts and community health & safety

d1 Will the sub-project involve temporary labor influx (more than 20 workers)?

d2 Will the sub-project cause traffic impacts and accessibility issues? d3 Could the sub-project cause utility damage? d4 Will the sub-project affect physical integrity of weak

structures/houses adjacent to worksites?

e. Occupational Health & Safety

e1 Will the sub-project involve potential physical hazards? e2 Will the sub-project involve fire hazards? e3 Will the sub-project involve slippage, falling & working at heights? e4 Will the sub-project involve manual handling and lifting? e5 Will the sub-project involve electrocution? e6 Will the sub-project involve excavation works?


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If the answer was “Yes” to any of the following questions, then the sub-project will trigger OP/BP 4.12, and the WB instruments needed (RAP or ARAP) should be identified.

c. Involuntary Resettlement Checklist 1. Require physical displacement of land owners/lessees/occupiers/squatters? 2. Require permanent/temporary land acquisition?

3. Cause loss of assets, restriction to assets, and loss of income sources or means of livelihoods?

4. Cause partial loss of income, partial damage of the land, and temporary restriction to assets?

Stage 3 – Simple monitoring checklist A simple monitoring ESMP checklist shall be used if none of the above questions (stages 1&2) was answered with “Yes”


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d. Monitoring ESMP – Checklist Project Proponent: …………………………..… Project Name: ………………………….............. Visit Date: …………………………………….... Participants: ……………………………………

Impact to check Yes No Remarks Safeguards/ Mitigation measures carried on

1 Noise generation 2 Dust spreading out 3 Odor emission

4 Traffic problems (hindering, detours, closure etc.)

5 Solid Waste Services problems 6 Sewerage Services problems 7 Water Services problems 8 Pedestrians' safety endangered

9 Landscape / aesthetic element/s deteriorated

10 Natural Resources negatively affected 11 Cultural/ historical objects/sites affected 12 Biodiversity and Wildlife threatened 13 Workers safety and health considered

14 Workers commitment to OHS (vests, gloves, Heavy Duty wearing apparel etc.)

15 Working machines suitability/ scaffolding

16 Improper storage of materials and equipment

17 Security incidents at the working site

18 Child labor observed

19

Additional Impact (please add it) ……………………………………… ………………………………………

20. Comments: …………………………………………………………………………………………………..

21. Recommendations: …………………………………………………………………………………………………………

Environmental and Social Safeguards Specialist's Signature……………………………………… Date………………………………………


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Annex V: Typical ESMP report content The ESIA report should include the following items as a minimum (not necessarily in the order shown):

a. Executive summary. Concisely discusses significant findings and recommended actions.

b. Policy, legal, and administrative framework. Discusses the policy, legal, and administrative framework within which the EIA is carried out. Explains the environmental requirements of any co-financiers. Identifies relevant international environmental agreements to which the country is a party.

c. Project description. Concisely describes the proposed project and its geographic, ecological, social, and temporal context, including any offsite investments that may be required (e.g., dedicated pipelines, access roads, power plants, water supply, housing, and raw material and product storage facilities, etc.). Indicates the need for any resettlement plan or indigenous peoples development plan (see also subparagraph (h) (v) below). Normally includes a map showing the project site and the project's area of influence.

d. Baseline data. Assesses the dimensions of the study area and describes relevant physical, biological, and socioeconomic conditions, including any changes anticipated before the project commences. Also takes into account current and proposed development activities within the project area but not directly connected to the project. Data should be relevant to decisions about project location, design, operation, or mitigatory measures. The section indicates the accuracy, reliability, and sources of the data.

e. Environmental and social impacts. Predicts and assesses the project's likely positive and negative impacts, in quantitative terms to the extent possible. Identifies mitigation measures and any residual negative impacts that cannot be mitigated. Explores opportunities for environmental enhancement. Identifies and estimates the extent and quality of available data, key data gaps, and uncertainties associated with predictions, and specifies topics that do not require further attention.

f. Analysis of alternatives (optional in a category B project). Systematically compares feasible alternatives to the proposed project site, technology, design, and operation - including the "without project" situation - in terms of their potential environmental impacts; the feasibility of mitigating these impacts; their capital and recurrent costs; their suitability under local conditions; and their institutional, training, and monitoring requirements. For each of the alternatives, quantifies the environmental impacts to the extent possible, and attaches economic values where feasible. States the basis for selecting the particular project design proposed and justifies recommended emission levels and approaches to pollution prevention and abatement.

g. Environmental and social management plan (ESMP). Covers mitigation measures, monitoring, and institutional strengthening; see outline in OP 4.01, Annex C.

h. Appendices would include:

(i) List of EIA report preparers--individuals and organizations.

(ii) References--written materials, both published and unpublished, used in study preparation.

(iii) Record of interagency and consultation meetings, including consultations for obtaining the informed views of the affected people and local nongovernmental organizations (NGOs). The record specifies any means other than consultations (e.g., surveys) that were used to obtain the views of affected groups and local NGOs.

(iv) Tables presenting the relevant data referred to or summarized in the main text.

(v) List of associated reports (e.g. resettlement plan or indigenous people’s development plan).


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Annex VI: Environmental Requirements for Contractors General 1. Assuming the preparation of a specific Environmental and Social Management Plan (ESMP) to address the above-mentioned specific issues. The Contractor shall be informed about such an ESMP for worksite of this Project, and prepare his work strategy and plan to fully take into account relevant provisions of that ESMP. 2. If the Contractor fails to implement the approved ESMP to fulfill his obligation within the requested time, the Client reserves the right to arrange for execution of the missing action by a third party on account of the Contractor. 3. The Contractor shall implement all measures necessary to avoid undesirable adverse environmental and social impacts wherever possible, restore worksites to the acceptable standards, and abide by the ESMP. 4. These provisions also apply to any sub-contractors present on Project’s worksites. General Environmental Protection Measures 5. In general, environmental protection measures to be taken at any worksite shall include:

5.1. Minimize the effect of dust on the environment resulting from earth mixing sites, vibrating equipment, construction related traffic on temporary or existing access roads, etc.

5.2. Ensure that noise levels emanating from machinery, vehicles and noisy construction activities (e.g. excavation, blasting) comply with Iraqi standards.

5.3. Ensure that existing water flow regimes in rivers, streams and other natural or irrigation channels are maintained and/or re-established where they are disrupted due to works being carried out.

5.4. Prevent any substances, including bitumen, oils, lubricants and waste water used or produced, from entering into rivers, streams, irrigation channels, and natural water bodies/reservoirs.

5.5. Avoid or minimize the occurrence of standing water in holes, trenches, borrow areas, etc. 5.6. Upon discovery of remains of archeological or historical importance during the, immediately report

to the Client (MOP/PMO). 5.7. Prohibit workers from exploiting natural resources: hunting, fishing, etc. 5.8. Prohibit the transport of firearms and/or third parties in Project-related vehicles. 5.9. Implement soil erosion control measures. 5.10. Ensure garbage, sanitation and drinking water facilities are provided at worksites. 5.11. Ensure that, local materials are used in lieu of transporting foreign materials, whenever possible. 5.12. Ensure public safety and avoid traffic accidents and comply with speed limits. 5.13. Ensure enough demarcation to any trench, pit, excavation, hole or other hazardous feature.

6. Besides the regular inspection of the sites by the supervisor appointed by the Client for ensuring adherence, the Client may appoint an E&S specialist to oversee the compliance with these environmental conditions and any proposed mitigation measures. Pipelines 7. No trench shall be left open for more than 7 days, unless duly authorized by the supervisor upon Contractor’s request. Provided enough demarcation 8. General conditions related with topsoil stripping, storage and restoration apply. Waste Management 9. All drums, containers, bags, etc. containing oil/fuel/surfacing materials and other hazardous chemicals (including oils from maintenance) shall be stored on a sealed and/or bonded area. All waste containers litter and any other wastes shall be disposed of at designated disposal sites as approved by relevant governorates and municipalities. 10. All drainage and effluent from storage areas, workshops, and worksites shall be captured and treated before being discharged into the drainage system, in line with water pollution control regulations. 11. Entry of runoff into construction sites, and worksites, shall be restricted by constructing diversion channels or holding structures such as berms, drains, dams, etc. 12. Construction waste shall not be left in stockpiles along the road, but removed and reused or disposed of on a daily basis. 13. Areas for temporary storage of hazardous materials such as contaminated liquid and solid materials shall be approved by the supervisor and appropriate local and/or relevant national or local authorities before the commencement of work. Disposal of such waste shall be in existing, approved sites. Rehabilitation of Worksites 14. Topsoil shall be stripped, removed and stored for subsequent rehabilitation. Soils shall not be stripped when wet, and not stored in large or high heaps. 15. Reinstate natural drainage patterns where they have been altered or impaired. 16. Remove toxic materials and dispose of in designated sites. Backfill with soils free of foreign material. 17. Ensure reshaped land is returned stable, and adequately drained. 18. Minimize erosion by wind and water both during and after the process of reinstatement.


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19. Compacted surfaces shall be deep ripped to relieve compaction unless dictated otherwise. Management of Water Needed for Construction Purposes 20. The Contractor shall at all costs avoid conflicting with water needs of local communities. Any temporary water abstraction for construction needs shall be consulted with community. Prior permit is required. 21. No construction water containing spoils or site effluent, especially cement and oil, shall be allowed to flow into natural water drainage courses, including wash water. 22. Site spoils/temporary stockpiles shall be located away from the drainage system and surface runoff. Traffic Management and Community Safety 23. Location of temporary access roads shall be done in consultation with the local community especially in important or sensitive environments. Access roads shall not traverse wetlands/ecologically sensitive areas. Consultations shall be documented. 24. Upon the completion of civil works, all temporary access roads shall be ripped and rehabilitated. 25. Measures shall be taken to suppress dust emissions generated by Project traffic. 26. Maximum speed limits for any construction-related traffic shall not exceed 50km/h in inhabited areas. Salvaging and Disposal of Obsolete Components Found by Rehabilitation Works 27. Obsolete materials and construction elements such as electro-mechanical equipment, electrical wires, pipes, accessories and demolished structures shall be salvaged and disposed of in a manner approved by the supervisor. The Contractor has to agree with the supervisor which elements are to be surrendered to the Client’s premises, which will be recycled or reused, and which will be disposed of at approved landfill sites. 28. Any asbestos cement material that might be uncovered when performing rehabilitation works will be considered as hazardous material and disposed of in a designated facility. Damage to Property 29. In case of damages to property, the Contractor shall repair to the owner’s satisfaction and at his own cost. A certificate from the owner/user shall be obtained for each repair. 30. For each repair, the Contractor shall obtain from the owner/user a certificate that the damage has been made good satisfactorily in order to indemnify the Client from subsequent claims. Contractor’s Health, Safety and Environment Management Plan (HSE-MP) 31. The Contractor shall prepare an HSE-MP within 6 weeks of signing the Contract. The Contractor’s EHS-MP shall provide:

31.1. a description of procedures and methods for complying with environmental management conditions, and any specific conditions specified in an ESMP;

31.2. a description of specific mitigation measures that will be implemented in order to minimize adverse impacts;

31.3. a description of all planned monitoring activities and the reporting thereof; 31.4. the internal organizational, management and reporting mechanisms put in place for such.

32. The Contractor’s HSE-MP will be reviewed and approved by MOP before start of the works. HSE Reporting 33. The Contractor shall prepare bi-monthly progress reports to the Client on compliance with these general conditions, the project ESMP, and his own HSE-MP. These to include:

33.1. HSE management actions/measures taken, including approvals sought from local or national authorities;

33.2. Problems encountered in relation to HSE aspects (incidents, including delays, cost consequences, etc. as a result thereof);

33.3. Non-compliance with contract requirements on the part of the Contractor; 33.4. Changes of assumptions, conditions, measures, designs and actual works in relation to HSE aspects;

and 33.5. Observations, concerns raised and/or decisions taken with regard to HSE management during site

meetings. 34. The reporting of any significant HSE incidents shall be done as soon as practicable, within an incident report. Records shall be kept. They could also be attached to progress reports. Training of Contractor’s Personnel 35. The Contractor shall provide sufficient training to his own personnel to ensure awareness on aspects of these general conditions, any project ESMP, and his own HSE-MP. Specific training will be provided to those Employees that have particular responsibilities associated with the implementation of the HSE-MP. Training activities will be documented for potential review by the MOP/PMO.

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