Environment & Social Safeguards

Environment & Social Safeguards
Kerala Urban Service Delivery Project (KUSDP)
Disclosure of draft ESMF for KUSDP-(Kerala Solid Waste Management Project)
Comments / suggestions if any in this regard may please be forwarded to
The Executive Director
Suchitwa Mission
Swaraj Bhavan
Base Floor (-1)
Nanthancode, Kowdiar P.O
e-mail: sanitation.sm@kerala.gov.in
Kerala Local Government Service Delivery Project- First phase of Kerala Urban Service Delivery Project (KUSDP)

Background: The Project Appraisal Document (PAD) and Project Implementation Manual (PIM) of Kerala Local Government Service Delivery Project (KLGSDP) mandatorily stipulates the integration of an Environment and Social Management Framework (ESMF) and Vulnerable Group Development Framework (VGDF) to be applied to sub-project activities taken up by LSGIs making use of the Performance Grant. Accordingly, an ESMF & VGDF has been developed for the project to ensure compliance with the applicable regulations and triggered safeguards policies. The ESMF will be applied to sub-projects to be taken up by LGs making use of the PGs provided to them under Component 1 of the Project. The long term vision of the integration of ESMF with the Performance Grant is that, in the future, the LSDG could consider the option to apply the ESMF to all activities taken up by the LSGs irrespective of the source of funds.

The ESMF comprises a detailed strategy and procedures for environmental and social appraisal (ESA) of sub-projects taken up by the LSGs. Potential adverse impacts to the environment are identified through a regulatory list and screening tool and can either be prevented or reduced by incorporation of appropriate mitigation measures, provided via Environmental Guidelines (EGs) in the ESMF. The ESMF also has a provision for carrying out Limited Environmental & Social Assessment (LESA) for cases where medium level impacts on the environment are expected. The ESMF contains institutional arrangements, capacity building plans and monitoring mechanisms to enable effective implementation of safeguard measures. Monitoring and evaluation of the ESMF will take place through the Annual Performance Assessment that has safeguards incorporated as assessment parameters through the Local Service Delivery Technical Evaluation, which will be undertaken by independent specialized agencies.

 Major stipulations of Environment & Social concerns under ESMF & VGDF:

Environment: KLGSDP falls in the environmental screening category “B” as per the Bank‘s Operational Policy 01. An Environmental Assessment (EA) was undertaken by the GoK and EA identified the following key environmental issues concerning the activities of LSGs: (i) depletion of natural resources, (ii) changes in land use and topography, (iii) non-permissible activities in forests, (iv) natural habitats or areas of historical significance, (v) soil erosion, (vi) inadequate waste disposal, (vii) usage of banned pesticides, and (viii) insufficient fodder resources. Accordingly, the Project triggers the following safeguard policies of the World Bank: Environmental Assessment (OP 4.01), Forests (OP 4.36), Natural Habitats (OP 4.04) and Physical Cultural Resources (OP 4.11).

Social: The social safeguard component of KLGSDP has been laid on the two major Operational Policies of World Bank, (i) Involuntary Resettlement (OP 4.12) and Indigenous Peoples Policy (OP 4.10). Since a robust process/institutional framework for addressing issues of Tribals and other vulnerable groups has been developed by Government of Kerala as part of their decentralized planning process and a substantial part the budget under Tribal Sub Plan (TSP) and Special Component Plan (SCP) flows through the LSG system in Kerala, the same system is adopted in the form of a Vulnerable Groups Development Framework (VGDF) which incorporates the requirements of tribal groups has been recognized. The VGDF has been developed based on detailed consultations with key stakeholders and has been integrated with the ESMF and disclosed.

Activities taken up by KLGSDP for the integration of ESMF & VGDF in Performance Grant:

Conducted a series of Capacity Building Trainings (Orientation, Refresher, Dissemination & Ad-hoc Trainings on ESMF & VGDF to LSGI Functionaries (Elected Representatives & Implementing Officers) by PMU, KILA & SIRD. Nearly 48 trainings have been conducted in this regard for the orientation and refresher of KLGSDP with special focus on ESMF &VGDF implementation to LSGIs during the project cycle. 4 Zonal Workshops have been carried out for the rolling out of Mid Term Environmental Audit followed by a State level and 14 District level Dissemination Workshops for the dissemination of Audit findings in 2014-15. In 2016-17, a State level Dissemination Workshop has been conducted following End of Term Environment Audit as well. In addition to these customized Trainings and Workshops, a series of Brain Storming Workshops and Orientation Trainings were carried out for ad-hoc activities such as ESMF Modification exercise, Pilot Social Audit process, Support to Backward LBs through NGOs for Need Assessment studies and DPR preparation exercises.

Efforts made for the Development of an Institutional Arrangements / Obligations during different stages of planning processes – project formulation, approval, implementation and monitoring stages. The ESMF procedures and protocols clearly stipulate the role and responsibilities of different tiers of LSGI Functionaries in the implementation of environment & social compliances in the planning and implementation process. Through different capacity building programs and surveillance mechanisms, this has been institutionalized and facilitated with the support of District units of KLGSDP and other relevant institutional mechanisms.

Successfully integrated required Tools & Proformas for environmental and social compliance in the Plan Software (Sulekha) of Information Kerala Mission (IKM). In addition to the publication of ESMF Document in the IKM and KLGSDP websites, relevant ESMF Proformas were translated to Malayalam language and incorporated in the plan software to make it user-friendly and easily adaptable to the LSGIs. Proper validations in the software were introduced to make the environment & social compliance verification form a compulsory document in KLGSDP subprojects at the time of DPR preparation.

Preparation and dissemination of effective IEC materials for creating awareness on the project in general and ESMF & VGDF in particular. To reiterate the knowledge and relevance of ESMF integration in KLGSDP subprojects, creative IEC materials such as Desktop Calendars, Newsletters, Success Stories, Website updates, Social media campaigns and information bulletins have been produced and disseminated to the LSGI functionaries on regular and need basis. Two Special Volumes of Success Stories have been produced and published on environmental & social due diligence with special focus on Natural Resources Management & Vulnerable Group Development.

Facilitation for the evolvement of good practices for Natural Resources Conservation & Management, Creation and maintenance of Critical Assets etc. and Projects to address Gender Based Violence: Different facilitation mechanisms have been developed and implemented through Workshops, Trainings and dissemination of IEC materials targeting these thrust areas. Subsequently, good numbers of projects have been evolved from Local Bodies for the reclamation of water bodies/water harvesting, reclamation of drinking water supply infrastructures, installation of sustainable energy supply infrastructures, construction and renovation of different kinds of community assets and public infrastructures, reclamation/renovation/preservation of heritage sites and monuments, critical assets such as crematoria, waste management facilities etc. Similarly, handful of projects to address Gender Based Violence also evolved from Local Bodies, which are the highlights of KLGSDP in these sectors.

Facilitated Projects targeting Vulnerable Groups using Performance Grant and a quiet good number of Subprojects targeting the following vulnerable groups have been evolved under KLGSDP. These projects have been well documented with the details on service aspects and number of beneficiaries. Some of the major projects targeting different vulnerable groups are given below:

  • Women (Kudumbasree Centres/Canteens, Skill Development Centres, Working Women’s Hostels etc.)
  • Children (Anganwadis, Schools, Parks, Stadiums etc.)
  • Scheduled Caste & Scheduled Tribes (Community Centres, Roads, Drinking water, Electrification etc.)
  • Destitutes (Old age homes, Day Care Centres etc.)
  • Physically & Mentally Challenged (Buds Schools, Day care Centres etc.)
  • Old Age people (Old age homes, Palliative care centres, Geriatric Units etc.)

Rolled out Pilot Social Audit in LSGIs following Social Audit Manual prepared under KLGSDP: On Government approval of Social Audit Manual prepared by State Institute of Rural Development (SIRD), initiated the task of a series of Capacity Building Trainings by KLGSDP at KILA in collaboration with Tata Institute of Social Sciences (TISS), Kerala Chapter. Training was offered to Village Social Auditors of the selected 27 GPs for piloting the social audit process in selected activities under Mahatma Gandhi National Rural Employment Guarantee Scheme (MGNREGS) and Integrated Child Development Scheme (ICDS). A total of 349 Village Social Auditors were trained in 6 batches and the trained Village Social Auditors completed the Social Audit in their respective LBs and submitted reports to KLGSDP for further mainstreaming and follow up activities by Government.

Approval of Modified ESMF document by World Bank & Government: One of the recommendations of the Mid Term Environmental Audit was the revision and modification of existing ESMF document to make it simpler and user-friendly for the stakeholders. A number of Consultation Workshops have been carried out in this regard participating Elected Representatives, Implementing Officers, and Officials from concerned Government Departments. World Bank & Government of Kerala reviewed and approved the modified ESMF Document for further implementation to KLGSDP Grant. The approved ESMF Document has been uploaded in KLGSDP, LSGD and IKM websites for further use by the LBs. A Refresher Training to this effect has been carried out to the District Coordinators of KLGSDP for further awareness and transmission to the LBs.

 Environment & Social Safeguards Surveillance Mechanism of KLGSDP

The Subproject DPRs approved for implementation by the District Planning Committees (DPC) have been screened and monitored by the District Units of KLGSDP during DPC approvals and also with field level verifications. Incorporation of Environment & Social Compliance verification form and relevant clearances as per the Regulatory List of ESMF has been strictly monitored.

A systematic and regular reporting by the District Units back to PMU on the screening and monitoring process of subprojects for their environmental & social due diligence for intervention by PMU, if required.

Submission of Annual Compliance Reports at the end of every fund cycle by PMU consolidating all field level informations and activities for review and recourse measures, if any required by Government and World Bank. Accordingly 4 Annual Compliance Reports have been prepared and submitted by KLGSDP to World Bank for completed 4 cycles of Performance Grant and 5th ACR is under preparation

Different evaluations were carried out by different External Agencies on the E & S compliance. Conducted 3 consecutive Annual Performance Assessments, where E&S concerns were a Minimum Mandatory Condition for the Grant eligibility and it was properly documented. Based on the guidelines of PIM and PAD, 2 Environmental Audits – one in the Mod-Term of the Project and one at the End of the Term of the Project has been carried out by external agencies and Environmental Audit Reports have been submitted to KLGSDP for follow up activities. A Rapid Impact Assessment study on the service delivery quality of projects intended for vulnerable groups and adherence of VGDF has been carried out after the mid-term of the project and report was submitted to KLGSDP. In addition to the two Environmental Audits, the End line Survey, End of Term Technical Evaluation and Capacity Building Evaluation carried out under the Component 3 of the Project satisfactorily reports the proper integration and awareness of ESMF to the field level under KLGSDP.

Outcome of the ESMF & VGDF integration in KLGSDP:

  • Successful in awareness generation drive on the ESMF & VGDF (Terminology, Triggering the Essentiality & Implementation Procedures, Documentation, Relevance with Performance Assessment) among the LB functionaries
  • Emergence of a Pool of trained LSGI functionaries at the formulation, approval & implementation level for Environment & Social compliance
  • Development of an institutional mechanism clearly depicting the obligations and responsibilities in Environment & Social compliance
  • Emergence of successful model projects complying Environment & Social Safeguards, with special focus on Natural Resources Management and Vulnerable Group Development complying the Environmental & Social Safeguard Operational Policies of World Bank and customized ESMF of KLGSDP.
  • Development ofstreamlined and modified ESMF document which could be mainstreamed to LSG activities (with required customization) irrespective of the funding sources, which was the long term vision of integrating ESMF in service delivery projects through KLGSDP.

ESMF Guidelines – Modified version

ESMF Guidelines – Old version

Envt Audit Report