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Sindh Education Reform Program (SERP) Environmental Impact Assessment And Environmental and Social Management Framework Reform Support Unit Education and Literacy Department Government of Sindh Pakistan April 18, 2009 E2116
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Sindh Education Reform Program (SERP)

Environmental Impact Assessment

And

Environmental and SocialManagement Framework

Reform Support UnitEducation and Literacy Department

Government of SindhPakistan

April 18, 2009

E2116

Sindh Education Reform Program (SERP)

Executive SummaryThe World Bank (WB) is negotiating to fund afresh the Sindh Education Reform Program (SERP) for 2008-2011. Earlier, WB funded the ongoing medium-term reform program for one year during 2007 when first annual development policy credit for US$ 100 million was released. The Bank in continuation of its commitment to the program is now planning to fund SERP under the proposed Sector Wide Approach (SWAp) mode of financing. In line with the WB safeguard policies and national regulations, an environmental assessment (EA) has been carried out for the proposed program. This document presents the process and outcome of this assessment.

Program OverviewThe key objective of the program is to improve access to quality primary and secondary education, with critical focus on reducing urban-rural divide and gender gap in enrolments. The program will be carried out by the Government of Sindh (GoS) through Education and Literacy Department (ELD) in partnership with twenty-three districts (district governments) in Sindh province.

SERP, a medium term sector reform program, is supported by four reform pillars comprising access, quality education, governance (sector management), and sustainability of expenditures. The main objectives of the reform program are to (i) provide minimal basic school infrastructure (access gap); (ii) improve learning and teaching environment at schools; (iii) reduce gender (boys-girls) and urban-rural gaps in enrolments; (iv) improve governance of educational institutions and schools particularly in districts; and (v) strengthen education institutions for effective delivery of services to public by introducing new approach to accountability and management reforms including linking education sector expenditures to targets and outputs (institutional strengthening and effective expenditures). Overall, the program has been designed to improve access to improve participation, retention and transition rates; reduce gender and regional disparities; and improve quality of elementary and secondary (Grade I-X) education. The program, however, has a particular focus on rural areas and girls.

The School Rehabilitation Program (access/supply side intervention) is one of the most important interventions under the ongoing reform program, and is comprised of three major components – construction of existing shelter-less schools; construction of additional class rooms; and provision of lacking/missing facilities to existing schools. The program covers both primary and secondary schools.

The School Rehabilitation Program (SRP) is implemented under the guidance of the ELD whereas the district governments are its implementation partners (IPs). Under the program, buildings including all basic minimal infrastructural facilities are provided to the existing shelter-less primary schools, provided the community donates the land for this purpose.

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SERP supports major initiatives such as annual school census, girls’ stipends, free and timely distribution of text books, teacher recruitment and development and education management policy reforms. The main thrust of the capacity building initiative under the program is provided by European Commission Sindh Education Reform Technical Assistance (EC SER TA) Grant.

Legal and Policy FrameworkThe Pakistan Environmental Protection Act of 1997 is the apex environmental legislation in the country, whereas the Operational Policy (OP) 4.01 provides the WB’s safeguard framework relevant to the proposed program. The present EA has been carried out in accordance with the national legislation and the WB operating policy.

Environmental Assessment and Environmental and Social Management FrameworkThe present environmental assessment (EA) of the proposed School Rehabilitation Program has been carried out using a screening matrix, which was tailor-made addressing the particular nature of the activities, as well as a comprehensive analysis of other important issues such as safety, hygiene and public health

The key potential environmental and safety issues related to the program include: (i) liquid and solid wastes generated during school construction and operation; (ii) lack of adequate measures, both at the design and construction stages, to address the schools´ vulnerabilities to natural disasters1 (both in new and rehabilitated schools); (iii) drinking water contamination2 and lack of adequate sanitation facilities; (iv) lack of education programs for children in personal hygiene and safety procedures during emergencies; (v) lack of low-cost renewable power systems in schools located in off-grid areas, resulting in an inadequate learning environment for children (excessive heat and poor lightning), and preventing the use of low-cost water decontamination techniques; and (vi) land acquisition issues3.

The project is not expected to trigger World Bank social safeguard policies. Two components are expected to have civil works that might require lands. It is expected that any such land needs which are expected to be quite minor will be addressed through use of public or communal lands, donations or leasing of private lands, or even market transactions. The Government Land Acquisition Act or World Bank OP 4.12 on Involuntary Resettlement will not be triggered.

Operational experiences and extensive planning work indicates that there are no indigenous peoples as defined under the World Bank policy in the project areas. Therefore World Bank OP 4.10 on Indigenous People is not triggered.

1 Mainly due to earthquakes, floods and landslides.2 Groundwater pollution by trace contaminants such as arsenic, fluoride; and in some cases by

biological contaminants (e.g., f. coliforms, v. cholera).3 Considering that: (i) the new public schools to be built will replace shelterless schools which already

have the necessary land; and (ii) in most cases, the public-private partnerships to establish new schools to be run by the private sector will use existing buildings to minimize the need of sizeable upfront investments, the likelihood of social problems related to land acquisition is very small.

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The Project has also planned a programmatic social assessment. It will be combined with the rigorous monitoring and evaluation system designed for the project. The social assessment will be focus on facilitating stakeholder participation during implementation, continuing exploring the various social factors underpinning quality to education, developing a gender dimension of various component programs and further screening component interventions for social safeguard impacts.

Though the significance of the potential negative impacts is expected to be low, mitigation measures have been proposed in the present EA, and an environmental and social management framework (ESMF) has been developed, in order to further reduce the probability and magnitude of the potential negative impacts and to improve the environmental performance of the program. The ESMF proposes a two-tier organizational structure with the overall environmental management responsibility assigned to the ELD (RSU), and the direct implementation responsibilities assigned to the District Government/its executing agencies (Implementation Partners - IPs). The GoS/ELD to provide also capacity building support to the partners to create awareness and help achieve environment management objectives.

The present EA has confirmed that the program will not result in any significant and/or lasting environmental impacts. It is also concluded that the present assessment is sufficient, and no further EA action is needed, in accordance with the national regulatory requirements as well as WB OP 4.01.

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AcronymsDG District Government DLI Disbursement Linked IndicatorDPC Development Policy CreditEA Environmental Assessment EC European CommissionEEP Eligible Expenditure ProgramEIA Environmental Impact Assessment ELD Education and Literacy DepartmentESMF Environmental and Social Management FrameworkGoP Government of Pakistan GoS Government of Sindh Ha HectareIDA International Development AssociationIEE Initial Environmental ExaminationIP Implementation Partner OP Operational PolicyPPP Public Private PartnershipRSU Reform Support UnitSEF Sindh Education FoundationSEMIS Sindh Education Management Information System SEPA Sindh Environmental Protection AgencySERP Sindh Education Reform Program SIL Specific Investment LoanSMC School Management CommitteeSRP School Rehabilitation Program SWAp Sector Wide ApproachTA Technical AssistanceTOP Terms of Partnership ToR Terms of Reference WB World Bank

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Contents

Executive Summary............................................................................ii

Acronyms ......................................................................................v

1 Introduction.............................................................................1-1

1.1 Program Description.....................................................1-1

1.2 Program Location.........................................................1-6

1.3 Document Structure......................................................1-7

2 Regulatory and Policy Review..............................................2-1

2.1 National Legislation, Regulations and Policies............2-1

2.2 WB Safeguard Policies.................................................2-1

3 Environmental Assessment..................................................3-1

3.1 Methodology.................................................................3-1

3.2 Findings of Environmental Assessment.......................3-1

4 Environmental Management Framework.............................4-1

4.1 Objective.......................................................................4-1

4.2 Management Approach.................................................4-1

4.3 Roles and Responsibilities............................................4-1

4.4 Environmental Guidelines............................................4-2

4.5 Environment, Safety, Public Health and Hygiene Trainings....................................................................4-2

4.6 Documentation and Reporting Mechanism..................4-2

5 Social Management Framework............................................5-1

5.1 Social Safeguards..........................................................5-1

5.2 Social Assessment........................................................5-2

6 Conclusions............................................................................6-1

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Exhibits

Exhibit 1.1: Program Location........................................................1-9Exhibit 1.2: Places of Archeological, Historical or Religious

Significance Falling in Sindh Province...................1-10Exhibit 1.3: Wildlife Protected Areas in Sindh............................1-12Exhibit 3.1: Screening Matrix..........................................................3-5Exhibit 4.1: Roles and Responsibilities.........................................4-4Exhibit 4.2: Preliminary Guidelines for the Design Phase...........4-6Exhibit 4.3: Preliminary Guidelines for the Siting and

Construction Phase.....................................................4-7Exhibit 4.4: Guidelines for the Operation Phase...........................4-8

Annexure

Annex 1: Implementation Strategy for the Environmental, Safety and Safeguards Aspects

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1 IntroductionThe World Bank (WB) is planning to support the ongoing Sindh Education Reform Program (SERP) in Sindh province of Pakistan under renegotiated lending instrument - Specific Investment Loan (SIL) with Sector Wide Approach (SWAp) that replaces earlier mode of financing – Development Policy Credit (DPC) series. The proposed program would support the implementation of SERP over a three year period – from 2008-09 to 2010-11, with proposed releases of US$ 100 million each year subject to achievement of annual performance benchmarks.

In line with the WB safeguard policies and national regulations, an environmental assessment (EA) of the proposed program has been carried out. This document presents the process and outcome of this EA.

1.1 Program DescriptionThe program aims to provide support to the on-going SERP under the SIL-SWAp financing instrument, replacing the earlier mode of DPCs, under which, the program received US$ 100 million in 2007 against the achievement of target performance benchmarks.

SERP is based on a Medium Term Sector Strategy (MTSS), and has been formulated around four key pillars comprising improved fiscal sustainability and effectiveness of public expenditures; improved education sector management; improved access to quality education particularly in rural areas and for girls; and improved quality of teaching and learning.

The program broadly aims at providing minimal basic school infrastructure/facilities (access gap); improving learning and teaching environment at schools; reducing gender (boys-girls) and urban-rural gaps in enrolments; improving governance of institutions and schools with special reference to districts ; strengthening education service delivery; improving education sector expenditures through institutional strengthening and effective oversight of expenditures.

Overall the whole program will be carried out by the Government of Sindh/Education and Literacy Department (ELD) in partnership with all 23 District Governments in Sindh.

1.1.1 District Terms of Partnership Policy Framework The GoS has introduced a performance based framework where-under an annual development (conditional grant) is provided to the partner districts (Implementation Partners-IPs) in Sindh under a pre-negotiated terms of partnership (TOP), concluded in the form of a TOP Agreement. The terms of partnerships are renewable for each following year. The conditional grant provided/committed is specifically to be utilized for School Rehabilitation Program (SRP) in accordance both with the program guidelines and GoS rules in force.

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The TOP Framework seeks to obtain bottom ownership from district stakeholders through the negotiated terms of partnerships. Under the TOP Framework, the grant is used as a leverage for encouraging districts to implement all the reform activities such as undertaking annual school census; improving girls’ stipend delivery system; quick distribution of text books; operationalization of closed/non-functional schools; teacher rationalization; activating school management committees; need based planning and development; approval of development schemes at district level; donor coordination at district level; education management reforms; quality education and so on.

The first phase of the TOP (TOP-I) was commenced in FY 2006/07 under WB’s DPC mode of financing. Under the first phase, all 23 district governments entered into pre-negotiated partnerships with the provincial government. Consequent to the signing of agreement, a conditional grant of Rs. 100 million, as committed under the agreement for undertaking school rehabilitation was released to each signatory district. The allocation under the first phased was equal across the board to encourage the partner districts to achieve performance targets in the following phase.

The first TOP Agreement contained a set of performance indicators which were agreed to by all the IPs. These indicators related to increase in gross enrolment (both boys and girls – primary to secondary); increase in the share of district’s own development outlay for education; increase in non-salary outlay for education; utilization rate of conditional grant; compliance to reporting requirements (Monthly Performance Reports – MPRs).

Based on these performance indicators (carrying total performance weight of 30 percent whereas the need carried 70 percent weight), the TOP grant for second phase (FY 2008-09) was worked out in accordance with the ‘need cum performance’ formula, approved by the RSU Steering Committee.

Second phase of the TOP now constitutes an important Disbursement Linked Indicator (DLI) under the renegotiated Sindh Education Reform Program (SERP) to be financed under the proposed SIL-SWAp arrangement.

This phase is based on a revised set of indicators. Since the TOP Framework has a major focus on rehabilitation of the existing primary/secondary schools in Sindh, the major additions include introduction of innovative Minimum Service Standards (MSS) for TOP schools, a concept introduced for the first time in Sindh, for improving infrastructural and operational standards of public schools in the province.

Under the second phase, the revised set of performance indicators have been linked to achieving the overall process improvements – planning to execution – with cross cutting impact on all SERP activities within IPs.

1.1.2 TOP-based School Rehabilitation Program The School Rehabilitation Program (SRP), which is a key component of SERP, is based on the agreed TOP with districts. SRP is aimed at reducing access gap by construction of shelterless primary schools, and providing additional class rooms and basic/lacking facilities such as drinking water, electricity, boundary walls and toilets.

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The first phase of School Rehabilitation Program (TOP-I/FY 2006-07) allowed inclusion of only the government primary (boys/girls/mixed) schools, identifiable with SEMIS IDs. A fixed maximum limit was also imposed on three subcomponents of schemes based on need based planning – shelterless schools (25%); additional class rooms (25%); and lacking/missing facilities (50%). These limits were fixed on the basis of SEMIS Analysis for school infrastructure gap and to also set direction for encouraging need based planning and development at district level. The TOP-I proposed 30% performance weight for following phase (TOP-II).

The second phase (TOP-II) plans to include both existing primary and secondary schools for civil works. The selection criteria will follow the original phase I guidelines read with minimum service standards for TOP Schools Part-III (Annexure-B of the TOP-II Agreement). The school works will be prioritized in such a way that it helps the district achieve its target performance indicators as set out in the Annexure-A of the TOP-II Agreement for FY 2008-09.

The TOP-II School Rehabilitation Program (FY 2008-09) carries a number of improvements. These are:

1. The provincial government has decided to engage a third party engineering consulting firm to provide top supervision of school construction( to ensure quality of construction), design support (to ensure school building designs are safe/stable in case of a natural disaster) and procurement review (ex post procurement audit for transparency);

2. Minimum Service Standards (MSS) for Schools have been designed for the first time under TOP-II, which should help guide partner districts to plan targets for their schools to achieve both minimal infrastructural and operational functionality;

3. Under the TOP-II/School Rehabilitation, an enhanced focus on environmental aspects has been envisaged. These aspects include improved energy efficient building designs, with consideration of flood and earthquake safety factors, provision of clean drinking water, provision of toilets/lavatory blocks with appropriate waste disposal arrangements, improved house-keeping during construction phase and environmental awareness raising for all stakeholders – district officials, contractors, school staff, students and community/SMCs.

4. Capacity Building through district/regional/provincial workshops/trainings for districts /concerned stakeholders in development and procurement planning, project execution; school planning and design and others.

5. TOP School Selection Committee (SSC) consisting of main stakeholders – Executive District Officer (Education), District Officer (Elementary), District Officer (Secondary), District Officer (SEMIS) and District Officer (Education Works/W&S), empowered to take informed decision for selection of school for civil works in each district.

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6. Prior physical survey of all proposed civil works/school locations by third party for certifying proposed work;

7. Each Taluka/town will have single contract for all the works proposed within it in order to attract quality contractors for these works;

8. Monthly Performance Reviews (by Districts themselves) and Quarterly Performance Reviews (by the provincial government/ELD/RSU/third party);

9. Expenditure tracking through newly allotted code of accounts for all SERP reform activities including School Rehabilitation;

10. Improved guidelines and process improvement with cross-cutting impact on need based planning and development – from planning to execution.

The first task under the program would be to conclude the TOP (II) Agreements with all the partner districts in Sindh, who will become Implementation Partners (IPs) under the SERP. ELD/RSU on behalf of the Govt. of Sindh would develop and employ appropriate criteria for the selection of the IPs.

The IPs would be responsible to select the TOP schools as per eligibility criteria; conduct prior physical survey of all proposed schools; facilitate the execution of the program guidelines (from planning to execution to environmental/ social); oversee the progress every month; endeavor to meet performance indicators as per TOP Agreement; ensure quality construction; and improve enrollment, teacher availability and community participation.

Under the agreement with the TOP IPs (partner districts), the TOP conditional grant will be transferred to Account-IV (District) from Account-I (Provincial). The funds so released shall be non-lapsable and will remain with the IPs till all the works are completed. The IPs will be responsible for all the procurements and construction will be undertaken by the private contractors selected through a transparent advertising process in accordance with the Govt. rules in force. The works will be undertaken in accordance with a design approved by the Works & Services Department, prepared with technical assistance arranged by the provincial government through engagement of a third party engineering consulting firm.

1.1.3 Capacity BuildingThe capacity building initiative under the proposed program of TOP based School Rehabilitation Program (SRP) would consist of two major components: training and skill development; and institutional support to districts. These components are described below.

Training and Skill DevelopmentThis component would seek to improve the quality of education, as well as impart trainings through district/province based workshops to District Focal Persons from the three stakeholder departments – Education, Works & Services and Finance.

Under the proposed program, the quality of education would be improved by the following measures: appointing local teachers through merit based recruitment policy;

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activation of school management committees through community mobilization campaign; operationalization of closed schools by providing teachers and required facilities; providing timely delivery of free text books to all existing public schools; providing stipends/scholarships to all eligible girls students (Class VI-X) at all public schools; proposing policy for teachers’ career and professional development; proposing policy for comprehensive education management reforms; effective sector wide donor coordination for need based intervention and control of duplication in development activities; improved data base for informed decision making; assessment of teaching and learning outcomes at schools for policy input; and so on.

Under the capacity building initiative, all district focal persons in the case of School Rehabilitation will be provided program orientation, training in procurement planning and execution, school design and risk control assessment including social & environment guidelines; effective project management and need based planning. Disaster management training is also on the cards during the three year program.

Institutional Support to District Governments The program also plans to support institutional strengthening of district education planning through donor coordinated efforts to ensure effective implementation of the initiative. The program would facilitate requisite processes and systems, which are critical for improving access to schools as well as raising the standard of education.

1.1.4 Public Private Partnership SERP also highlights the role of public-private partnerships (PPP) in enhancing access to quality education as well as meeting the demand for education in the province. To this end, the Sindh Education Foundation (SEF), the organization responsible for undertaking PPP-based school operations in the province, was established through the GoS Ordinance. Later, SEF underwent restructuring in order to sustain the PPP initiatives under its belt, chiefly ‘the Grant-in-Aid Program’ and the ‘Adopt-a-School Program, which were initiated as part of the SEF’s PPP portfolio during the 1990s.

The Foundation’s initiatives under the Public Private Partnership (PPP) include foremost the Adopt-a-School Program (AASP) which became a pioneering initiative that encouraged private sector patronage of public sector schools. The AASP has been recognized at the national level and replicated across the other provinces of the country by their respective Education Foundations.

Given its experience and expertise in implementing a huge PPP portfolio through a dedicated team of professional staff, the Sindh Education Foundation seeks to expand its scope of work. This particular program proposal aims to establish greater public private partnerships for increasing access to and improving the quality of educational services provided to the children in marginalized areas of the Sindh province through supporting private entrepreneurs. The program will bring some key partners together in order to concentrate on the enhancement of access and quality of educational services in the country.

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Proposed Program Goal and ObjectivesThe proposed program will extend support, both financial and academic, to new private coeducational primary schools set up in marginalized areas of the province of Sindh. The program seeks to establish public private partnerships for increasing access to and improving the quality of educational services provided to the children in the marginalized areas of the Sindh province.

Under the PPP initiative, the following two schemes will be offered:

Scheme A - Base Model: Under this scheme, a set of 100 randomly-selected qualifying localities (e.g., villages) in the pilot districts will receive private schools. Scheme A will provide the following benefits:

Per-child enrollment subsidy which will be equal for both boys and girls;

Teacher and administrator training and school capacity building; and

Monitoring and learning support to the schools.

Scheme B - Base Plus Model: Under this scheme, another set of 100 randomly-selected qualifying localities in the pilot districts will receive private schools. Scheme B will provide the following benefits:

Per-child enrollment subsidy with a higher subsidy amount for girls;

Teacher and administrator training and capacity building; and

Monitoring and learning support to the schools.

1.2 Program LocationThe program will be implemented throughout the twenty-three districts of the Sindh province. Sindh is the second largest province of Pakistan. The neighboring regions are Balochistan to the west and northwest, Punjab in the north, Rajasthan (India) to the east and the Arabian Sea and Gujarat (India) to the south (Exhibit 1.1 presents a map of the Province). The province forms the lower Indus basin and lies between 23º and 28º North latitudes and 66º and 71º East longitudes. It is about 579 km in length from north to south and nearly 442 km in its extreme breadth (281 km average). It covers an area of 140,914 km2.

The overall literacy of Sindh is 45.29 percent (1998 census data). The urban literacy is 63.72 percent which is substantially higher than the rural literacy which is 25.75 percent. At about 24 percent, the overall educational enrolment in the entire Sindh province is also quite dismal.

There exist a large number of sites of archeological, cultural, historical and religious significance in Sindh. The major ones include the archeological remains at Moen-Jo-Daro, which is one of the most important Indus Civilization sites, and the Makli Hills graveyard in the Thatta district. In addition, a large numbers of shrines exist in almost all parts of the project area. A list of these places located in the project area districts is provided in Exhibit 1.2.

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The entire area of Sindh is located in the Indus Basin, which essentially forms the western extension of Indo-Gangetic Plain, and has been made up of the silt brought by the Indus and its numerous tributaries, such as Jhelum, Chenab, Ravi and Sutlej on the east bank, and Kabul, Kurram, Tochi, and others on the west bank. The Indus Plain is known for its agricultural fertility and cultural development throughout history.

The left bank tributaries of the Indus River all meet at Panjnad and flow as one large stream for about 75 km before joining the Indus at Mithankot, and south of it, the Indus flows almost alone up to the Arabian Sea without receiving any noticeable tributary.

The average annual discharge of the Indus – 92 million acre feet (MAF) at Attock Khurd – is much higher than the combined discharge of its tributaries. There is a great fluctuation in their seasonal discharge, especially in the hot summer and rainy season. Almost all of its tributaries and the Indus itself have their sources in snow and glaciated areas of Himalayan, Karakoram and Hindukush mountain systems.

On the basis of hydrology and land form, the Indus Plain can be divided into the Upper and Lower Indus Plains. The Upper Indus Plain differs from the Lower Indus Plain (the Sindh Province) primarily because of the major tributaries (Jhelum, Chenab, Ravi and Sutlej) divide the land surface into several interfluves or ‘doabs’. The two plains are separated by a narrow corridor near Mithankot where the Sulaiman range approaches the Indus River. The Lower Indus Plain (Sindh Province) is very flat, generally sloping to the south with an average gradient of 95 mm per km (6 inches per mile). Sindh can be divided in five distinct micro-relief land forms: active flood plain; meander flood plain; cover flood plain; scalloped interfluves; and the Indus delta. In the northeast, the meander flood plain is more extensive, while in the central and lower Indus Plain, the cover flood plain is more prominent. Topographically, Sindh can be divided into four distinct parts with the dry and barren Kirthar Range in the west, a central alluvial plain bisected by the Indus River, a desert belt in the east, and the Indus delta in the south.

There exist one national park, thirty-three wildlife sanctuaries and sixteen game reserves in the Sindh province. A list of these protected areas is provided in Exhibit 1.3.

1.3 Document StructureChapter 2 describes the Pakistan’s legislative and regulatory and World Bank’s policy framework for environmental management relevant to the proposed program.

Chapter 3 presents the environmental assessment methodology adopted during the present EA, and also identifies the key environmental concerns associated with the proposed program.

Chapter 4 presents the proposed the environmental management framework, which is essentially a mechanism for the implementation of the environmental management measures.

Chapter 5 presents the social aspects related to SERP.

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Finally, Chapter 6 presents the conclusion of the studies carried out.

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Exhibit 1.1: Program Location

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Exhibit 1.2: Places of Archeological, Historical or Religious Significance Falling in Sindh Province

Badin District1. Ruins of old city at Badin.Hyderabad District2. Tomb of Ghulam Shah Kalhora, Hyderabad.3. Boundary Wall of Pucca Fort, Hyderabad.4. Old office of Mirs, Hyderabad Fort, Hyderabad.5. Tajar (Treasury) of Mirs, Hyderabad Fort, Hyderabad.6. Tomb of Ghulam Nabi Khan Kalhora, Hyderabad.7. Buddhist Stupa, (Guja) a few miles from Tando Muhammad Khan, Hyderabad.8. Haram of Talpur Mirs, Hyderabad.9. Enclosure containing Tombs of Talpur Mirs, Hyderabad.10. Tower (Now used as water tank), Hyderabad Fort, Hyderabad.11. Two Mosques and a Tomb, Tando Fazal, Hyderabad.12. Tomb of Sarfaraz Khan Kalhora, Hyderabad.13. Nasar-ji- Mosque, Mohalla Jhambhas, Nasarpur, Hyderabad.14. Kiraiji Masjid, Mohalla Misri, Nasarpur, Hyderabad.15. Mai Khairiji Masjid, Mohalla Memon, Hyderabad.16. Mosque of Mirs, Hyderabad, ward “E”, Hyderabad.17. Enclosure containing Tombs of Talpur Mirs, Hyderabad.Larkana District18. Jhukar mound, Mithadaro, Larkana.19. Moenjodaro, Buddhist monastery and prehistoric remains around Moenjodaro, Larkana.20. Moenjodaro, Buddhist Stupa and prehistoric remains underneath, Moenjodaro, Larkana.21. Tajjar Building, Jinnah Bagh, Larkana.22. Tomb of Shah Baharo, Larkana.23. Square Tower, near Dhamrao, Larkana.24. Dhamrao Dero (three groups), Deh Dhamrao, Deh 67 Nasrat, Larkana.Sanghar District25. Brahmanabad (Mansura) locally known as Dalo Raja-ji-Nagri, Jamara, Tehsil Sinjhoro.

Deh Dalore, Sanghar.26. Mound Thulh, Deh Kot Bujar, Sanghar.27. Graveyard, Tehsil Shahdadpur, Sanghar.Thatta District28. Brick dome to the north-east of tomb of Mubarak Khan (tomb of Fateh Khan’s sister),

Makli Hill, Thatta.29. Tomb of Mubarak Khan son of Jam Nizamuddin, Makli Hill Thatta.30. Tomb and compound wall of yellow stone to the south of Jam Nizamuddin, Makli Hill,

Thatta.31. Tomb and enclosure to the south-west of S. No. 92. Makli Hill, Thatta.32. Tomb and enclosure to the west of the above tomb S. No. 93, Makli Hill, Thatta.33. Brick dome to the south of the tomb S. No 94, above Makli Hill, Thatta.

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34. Sultan Ibrahim and other tombs also but wrongly known a Amir Khalil Khan’s tomb, Makli Hill, Thatta.

35. Tomb and compound wall of yellow stone to the south of Mirza Muhammad Baqi Tarkhan tomb (wrongly called Mirza Isa Khan’s tomb), Makli Hill, Thatta.

36. Brick enclosure of Mirza Baqi Baig Uzbak’s tomb, south of the tomb of Nawab Isa Khan the younger, Makli Hill, Thatta.

37. Dabgir Masjid, Makli Hill, Thatta.38. Graveyard, Makli Hill, Thatta.39. Goth Raja Malik graveyard known as Maqam Qadar Shah, Deh Raja Malik, Thatta.40. Sonda graveyard, village Sonda, Thatta.41. Jam Nizmuddin’s tomb, Makli Hill, Thatta.42. Baradari, Makli Hill, Thatta.43. Tomb of Amir Sultan Muhammad son of Amir Hajika, Makli hill, Thatta.44. Tomb of Nawab Isa Khan, the younger Makli Hill, Thatta.45. Mirza Tughral Baig’s tomb, Makli Hill, Thatta.46. Tomb of Mirza Jani and Mirza Ghazi Baig, Makli Hill, Thatta.47. Stone enclosure containing tombs of Nawab Isa Khan, Makli Hill, Thatta.48. Mirza Muhammad Baqi Tarkhan’s tomb (wrongly called Mirza Isa Khan’s tomb) Makli Hill,

Thatta.49. Stone tomb with a dome on stone pillars by the side Mirza Jani Baig’s tomb, Makli Hill

Thatta.50. Brick masjid and enclosure near Nawab Shurfa Khan’s tomb (supposed to be the tomb of

Sayyed Amir Khan), Makli Hill, Thatta.51. Stone tomb with enclosure to the south of tomb of Mirza Muhammad Baqi Tarkhan, Makli

Hill, Thatta.52. Tomb of Mirza Muhammad Isa Turkhan I, Makli Hill, Thatta.53. Brick tomb near the tomb of Qulia pir, Makli Hill, Thatta.54. Tomb with superstructure on stone pillars to the north of tomb of Jam Nizamuddin, Makli

Hill, Thatta.55. Brick structure to the north of tomb of Jam Nizamuddin, Makli Hill, Thatta.56. Two pavilions on stone pillars over the tombs to the southwest of tomb of Jam

Nizamuddin. One is the tomb of Jam Sikandar Shah, Makli Hill, Thatta.57. Kalan Kot, Makli Hill, Thatta.58. Nawab Amir Khan’s mosque, Makli Hill, Thatta.59. Building with two domes near the Civil Hospital, Thatta, Makli Hill, Thatta.60. Jama Masjid, Makli Hill, Thatta.61. Sasian-Jo-Takar (Mirpur Sakro, Thatta.62. Jama Masjid, Thatta.

WORLD HERITAGE MONUMENTS ON UNESCO LIST.

1. Mohenjodaro, District Larkana.2. Makli Hill, Thatta.

Source: Guidelines for Sensitive and Critical Areas. Government of Pakistan. 1997.Note: None of the above areas are located at or in the immediate vicinity of the proposed project components.

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Exhibit 1.3: Wildlife Protected Areas in Sindh

Protected Area Name Area (ha) Classification Coordinates

Bijoro Chach 121 Wildlife Sanctuary Not Recorded

Cut Munarki Chach 405 Wildlife Sanctuary Not Recorded

Deh Akro/Nara Canal 20,000 Wildlife Sanctuary 27/42 N. 68/52 E.

Deh Jangisar 314 Game Reserve Not Recorded

Deh Khalifa 429 Game Reserve Not Recorded

Deh Sahib Saman 349 Game Reserve Not Recorded

Dhoung Block 2,098 Wildlife Sanctuary Not Recorded

Dograyon Lake 648 Wildlife Sanctuary Not Recorded

Dosu Forest 2,312 Game Reserve Not Recorded

Drigh Lake 164 Wildlife Sanctuary Not Recorded

Ghamot 27,283 Game Reserve Not Recorded

Ghondak Dhoro 31 Wildlife Sanctuary Not Recorded

Gullel Khon 40 Wildlife Sanctuary Not Recorded

Gulsher Dhand 24 Wildlife Sanctuary Not Recorded

Hadero Lake 1,321 Wildlife Sanctuary 24/50 N. 67/53 E.

Hala 954 Game Reserve 25/48 N. 68/25 E.

Haleji Lake 1,704 Wildlife Sanctuary 24/49 N. 67/44 E.

Hilaya 324 Wildlife Sanctuary Not Recorded

Indus River 44,200 Game Reserve 28/24 N. 69/45 E.

Keti Bunder South 8,948 Wildlife Sanctuary 24/08 N. 67/27 E.

Keti Bunder North 23,040 Wildlife Sanctuary 24/08 N. 67/27 E.

Khadi 81 Wildlife Sanctuary Not Recorded

Khairpur Game Reserve Not Recorded

Unclassified 27/32N. 68/47 E.

Khanpur Not Recorded

Unclassified Not Recorded

Khat Dhoro 11 Wildlife Sanctuary Not Recorded

Khipro 3,885 Game Reserve 25/49 N. 69/21 E.

Kinjhar (Kain) Lake 13,468 Wildlife Sanctuary 29/54 N. 70/57 E.

Kirthar 308,733 National Park 25/44 - 27/15 N. 67/10.E

Kot Dinghano 30 Wildlife Sanctuary Not Recorded

Lakht 101 Wildlife Sanctuary 26/36 N. 67/53 E.

Langh (Lungh) Lake 19 Wildlife Sanctuary 27/30 N. 68/03 E.

Mahal Kohistan 70,577 Wildlife Sanctuary Not Recorded

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Protected Area Name Area (ha) Classification Coordinates

Mejiran 24 Wildlife Sanctuary Not Recorded

Mando Dero 1,234 Game Reserve Not Recorded

Marho Kohn 162 Wildlife Sanctuary Not Recorded

Miani Dhand 57 Wildlife Sanctuary 25/27 N. 68/23 E.

Mirpur Sakro 777 Game Reserve 24/32 N. 67/38 E.

Mubahat Dero 16 Wildlife Sanctuary Not Recorded

Munarki 12 Wildlife Sanctuary Not Recorded

Nara 109,966 Game Reserve 27/42 N. 68/52 E.

Nara Desert 223,590 Wildlife Sanctuary Not Recorded

Norang 243 Wildlife Sanctuary Not Recorded

Pai 1,969 Game Reserve Not Recorded

Pir Mahfooz Game Reserve

Not Recorded

Unclassified Not Recorded

Pir Pagara Game Reserve Not Recorded

Unclassified Not Recorded

Runn of Kutch 320,463 Wildlife Sanctuary Not Recorded

Sadnani 84 Wildlife Sanctuary Not Recorded

Samno Dhand 23 Wildlife Sanctuary Not Recorded

Shah Lanko 61 Wildlife Sanctuary Not Recorded

Surjan, Sumbak, Eri and Hothiano

40,632 Game Reserve 25/25 N. 67/55 E.

Takkar 43,513 Wildlife Sanctuary 27/15 N. 68/49 E.

Tando Matha Khan 5,343 Game Reserve Not Recorded

Source: Guidelines for Sensitive and Critical Areas. Government of Pakistan. 1997.

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2 Regulatory and Policy ReviewThis Chapter briefly describes the legislative and policy framework relevant to the proposed program.

2.1 National Legislation, Regulations and Policies

The cornerstone of environmental legislation is the Pakistan Environmental Protection Act of 1997 (PEPA) which superseded the Pakistan Environmental Protection Ordinance of 1983. The Act establishes the general conditions, prohibitions, and enforcement for the prevention and control of pollution, and the promotion of sustainable development. The Act also establishes and delineates the powers and functions of the Pakistan Environmental Protection Council (PEPC), Pakistan Environmental Protection Agency (Pak-EPA), provincial Environmental Protection Agencies (EPAs), and Environmental Tribunals. In particular, the Act creates the authority for delegation of environmental management functions to the provincial EPAs. Nothing in the Act prohibits provincial governments from adopting more stringent standards or regulations.

Under the PEPA, the Federal government has the authority to delegate any of its environmental management functions and powers to provincial governments, government agencies, or local authorities. Provincial governments in turn may delegate powers to any lower-tiered government agency. This provision establishes a framework for environmental federalism within which environmental management responsibilities are shared among Federal, provincial and local governments. Environmental federalism is built on the belief that governance is strongest when implemented at the level closest to the beneficiary, and is further promoted in Pakistan by the Local Government Ordinance of 2001, which introduced a new system of local government aimed at promoting responsibility at the local level. According to this Ordinance, rural and urban local councils are responsible for “the prevention of pollution of water or land from such sources and in such manner as the by-laws may provide.”

According to PEPA, no development program can be undertaken unless an initial environmental examination (IEE) or an environmental impact assessment (EIA) is conducted, and approval is received from the federal or relevant provincial EPA. The categories of programs, for which an EIA or IEE has to be carried out, are defined in the Pakistan Environmental Protection Agency Review of IEE and EIA Regulations, 2000. In Sindh the guidelines for the preparation of IEE and EIA are the same general guidelines that were prepared by Pak-EPA in 2000.

The present EA has been carried out in accordance with the above-mentioned legislation.

2.2 WB Safeguard PoliciesThe program was also analyzed against the WB safeguard policies: OP 4.01 (environmental assessment), OP 4.04 (natural habitat), OP 4.36 (forestry), OP 4.09

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(pest management), OP 4.11 (cultural property), OP 4.37 (safety of dams), OP 7.50 (projects in international waters), and OP 7.60 (projects in disputed areas).

The above-mentioned OPs and their applicability to the present program are discussed in the following table:

OP 4.01 Environmental Assessment

This OP requires environmental assessment (EA) of projects proposed for Bank financing to help ensure that they are environmentally sound and sustainable. This OP also categorizes the projects on the basis of the type, location, sensitivity, and scale of the project and the nature and magnitude of its potential environmental impacts.

The SERP has been classified as Category B, and the present ESMF has been developed in response to this OP.

OP 4.04 Natural Habitat The conservation of natural habitats, like other measures that protect and enhance the environment, is essential for long-term sustainable development. Through this OP, the WB therefore supports the protection, maintenance, and rehabilitation of natural habitats and their functions.

The program includes limited amount of construction work related to expansion of existing school buildings, provision of missing facilities in the existing schools and construction of buildings for the existing shelter-less schools. None of these activities will affect any of the natural habitats. Therefore, the OP is not triggered.

OP 4.36 Forestry The objective of this Policy is to assist the WB’s borrowers to harness the potential of forests to reduce poverty in a sustainable manner, integrate forests effectively into sustainable economic development, and protect the vital local and global environmental services and values of forests.

As mentioned above, the physical works during the proposed program will be carried out at the existing facilities which are in settled areas. Hence no forest area is likely to be affected, and therefore, this OP is also not triggered.

OP 4.09 Pest Management

Through this OP, the WB supports a strategy that promotes the use of biological or environmental control methods and reduces reliance on synthetic chemical pesticides.

This OP is not applicable since the proposed program

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does not involve any activities relating to agriculture, use of pesticides, fertilizer or other chemical inputs.

OP 4.11 Cultural Property

The World Bank’s general policy regarding cultural properties is to assist in their preservation, and to seek to avoid their elimination.

As discussed above, the program involves civil works at the existing school locations which are located in settled areas. Hence no cultural property is likely to be affected which may trigger the OP. However, the ESMF includes guidelines, should any such property is discovered during the implementation.

OP 4.37 Safety of Dams

The Policy seeks to ensure that appropriate measures are taken and sufficient resources provided for the safety of dams the WB finances.

This OP is not applicable since program does not involve any work relating to dam construction.

OP 7.50 Projects in International Water

This OP defines the procedure to be followed for projects the WB finances that are located on any water body that forms a boundary between, or flows through two or more states.

This OP is not applicable since the program does not involve any works on water base.

OP 7.60 Projects in disputed areas

Projects in disputed areas may raise a number of delicate problems affecting relations not only between the Bank and its member countries, but also between the borrower and one or more neighboring countries. In order not to prejudice the position of either the Bank or the countries concerned, any dispute over an area in which a proposed project is located is dealt with at the earliest possible stage.

This OP is not applicable as no disputed areas exist in the province of Sindh.

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3 Environmental Assessment This Chapter assesses the potential negative impacts of the proposed program on various aspects of the environment.

3.1 MethodologyThe present environmental assessment was carried out using a standard methodology, in line with the national regulations and WB safeguards described above. The assessment was initiated with review of the program information. Subsequently, a field visits (Districts- Thatta and Hyderabad) were carried out, during which some existing schools were visited. Discussions were also held with some of the school management and teachers. In addition, meetings were held with some key stakeholders, including the Sindh Environmental Protection Agency (SEPA), Sindh Education Foundation (SEF), Works & Services Department, and NED University of Engineering & Technology, Karachi.

After the field investigations, environmental assessment of the proposed program was carried out employing a screening matrix, which was tailor-made according to the specific needs of the program. The screening exercise was complemented with a comprehensive analysis of other important issues such as safety, hygiene and public health.

The screening matrix examined the interaction of program activities with various components of the environment. The program activities included construction of additional classrooms and provision of missing facilities and construction of existing shelter less schools, whereas the environmental parameters were broadly classified as physical, biological and social, and then each of these broad categories further divided into different aspects. The potential impacts thus predicted were characterized as follows:

High negative (adverse) impact,

Low negative impact,

Insignificant impact,

High positive (beneficial) impact,

Low positive impact, and

No impact.

The screening matrix for the proposed program is provided in Exhibit 3.1.

3.2 Findings of Environmental AssessmentThis section discusses the findings of the environmental assessment carried out for the proposed program.

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3.2.1 Concerns relating to School DesignsAs shown in Exhibit 3.1, the key environmental concerns associated with school design relate to the following aspects:

Surface and groundwater contamination caused by improper design of sewage disposal;

Public health issues caused by reasons as mentioned above as well as lack of provision of clean drinking water (arsenic and fluoride contamination, fecal coliforms and others);

Safety issues associated with improper structural design with respect to natural disasters (such as earthquakes and floods);

Gender issues associated with lack of provision of separate toilets for boys and girls in schools.

The above problems pose significant risks to the lives of thousands of children and teachers, and so far very little have been done to minimize these risks. Recent seismic events in Pakistan and China which resulted in high children fatality inside schools demonstrate the seriousness of the problem. During the project preparation, analytical work is being carried out with World Bank support to assist the GoS to identify and assess the magnitude of such problems, and to design measures to address them.

Although a significant amount of data is available in Pakistan regarding the location of areas with high of natural disasters, as well as locally developed research results concerning low-cost methods to reinforce existing small structures and to improve the design of the new ones, the knowledge of this vital information is compartmented and restricted to a few people directly involved in the data collection and/or research activities. Therefore, it is extremely important the implementation of measures to disseminate the available information to a wider audience, including top officials of the GoS.

In addition to drinking water quality problems, the majority of the schools in Sindh don’t have adequate sanitation facilities, either because they do not exist, have been poorly designed and built, are insufficient for the number of students, or are in such a state of disrepair (due to lack of maintenance), that no children can use them. The existence of adequate operating sanitation facilities is particularly important in the case of girls, and their absence may discourage parents to enroll their daughters in the schools, thus contributing to defeat one of the main objectives of SERP.

An implementation plan for gradually addressing issues related to inadequate sources of drinking water and poorly designed and built sanitation facilities, school buildings vulnerability to natural disasters, and for improving school design, construction, and maintenance standards and a third party supervision protocol, as well as renewable power supply for off-grid schools, is under preparation and will be supported (by DLIs and TA) under the project. Concerns associated with School Construction

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A low level of negative environmental impacts is expected to be experienced during the construction phase of the schools. These include:

potential increase in water scarcity during construction activities (in water-scarce areas),

possible contamination of water because of improper waste disposal, and associated public health concerns;

safety hazard for the students, school staff and the community – associated with the construction activities;

poor structural quality of the schools buildings due to lack of adequate construction supervision;

loss of natural vegetation and/or loss of agriculture as a result of the construction activities.

However most of the above issues are temporary in nature and will disappear as soon as the building is complete. Furthermore, due to the smallness of the individual school buildings, the magnitude of these impacts will be small. Hence most of these impacts have been characterized as ‘low negative impacts’ in Exhibit 3.1.

The probability and consequence magnitude of these impacts will further be decreased by employing basic and well known impact mitigation measures – such as waste collection and appropriate disposal, avoiding areas of significant natural vegetation and prime cultivation/orchard lands, as well as the hiring of a third party construction supervision firm that will ensure that all buildings are properly built and safe for teachers and children.

The environmental guidelines to address the above concerns have been developed and provided in the next Chapter. The contractors will be required to follow these guidelines when carrying out the construction activities.

3.2.2 Concerns associated with School OperationThe following types of environmental concerns can potentially arise during various phases of school operation (both the government as well as PPP schools):

health concerns associated with missing/non-functioning clean drinking water facility

health concerns associated with missing/non-functioning sanitation facilities;

surface and ground water contamination caused by improper waste disposal (missing/non-functioning sewage disposal systems)

risk of communicable diseases such as Hepatitis B, Typhoid, and Cholera

Lack of access to clean drinking water and poor or no sanitation facilities at the schools can pose a health risk to the students, teachers and the nearby community. Arrangement of appropriate toilet facility and its proper functioning, as well as raising awareness of the teachers as well as students in matters such as personal hygiene

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will greatly address this issue. Through the present program, these important issues will be addressed. The clean drinking water and appropriate sanitation facilities will be included in the design of the school buildings (as discussed in Section 3.2.1 above), and during the school inspections, it will be ensured that these facilities are in proper working condition and fully functional. These aspects will also be included in the scope of the engineering/construction supervision firm to be hired during the proposed program for this purpose.

The risks of other communicable diseases can be reduced through the implementation of the government’s occasional vaccination drives. Raising awareness level and disseminating information among the administrators, teachers and students on precautionary measures will also greatly reduce if not eliminate this risk. Appropriate communication materials, such as wall charts, should be used to disseminate information and raise awareness in this respect. These capacity building/awareness raising aspects will also be included in the proposed program.

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Exhibit 3.2: Screening Matrix

Physical Biological Social and Socioeconomic

Soi

l Ero

sion

/ C

onta

min

atio

n

Air

Qua

lity

Sur

face

Wat

er Q

ualit

y

Gro

undw

ater

Qua

lity

Wat

er A

vaila

bilit

y an

d C

onsu

mpt

ion

Nat

ural

Veg

etat

ion

Wild

life

Blo

cked

Acc

ess

Rou

tes

Noi

se a

nd V

ibra

tion

Agr

icul

ture

Use

of A

gro

Che

mic

als

Live

stoc

k G

razi

ng

Com

pens

atio

n Is

sues

Saf

ety

Haz

ards

(e.g

. flo

ods

and

earth

quak

es)

Em

ploy

men

t/Ear

ning

Opp

ortu

nitie

s

Pub

lic In

frast

ruct

ure

Pub

lic H

ealth

(hyg

iene

and

sa

nita

tion)

Aes

thet

ic V

alue

Con

flict

s an

d C

ultu

ral I

ssue

s

Gen

der I

ssue

s

Site

s of

Arc

heol

ogic

al, H

isto

rical

or

Cul

tura

l Sig

nific

ance

Impa

cts

on In

dige

nous

Peo

ple

TOP Schools School Design N N -2 -2 N N N N N N N N N -2 N N -2 -1 N -2 N NConstruction Activities (SHE, ACR, MF) -1 0 -1 -1 -1 0 N 0 -1 -1 N 0 N -2 +2 0 -2 0 0 0 0 N

School Operation -1 N -2 -2 -1 N N N N N N N N N +1 N -2 N N -1 N NPPP-SEF Schools

School Operation -1 N -2 -2 -1 N N N N N N N N N +1 N -2 N N -1 N NKey: -2: High negative impact; -1: Low negative impact; 0: insignificant/negligible impact; +1: low positive impact; +2: High positive impact, N: no impact.

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4 Environmental Management Framework

This Chapter provides the environmental management framework (EMF), which has been developed in order to address the environmental concerns discussed in Chapter 3 above.

4.1 ObjectiveThe objective of the EMF is to provide a mechanism to manage the environmental issues that may arise during the proposed activities, particularly the design, construction and operation of schools. The EMF defines the roles and responsibilities of various stakeholders and also provides guidelines to be followed during the program implementation of the TOP-based School Rehabilitation Program (SRP) under Sindh Education Reform Program (SERP).

4.2 Management ApproachThe overall responsibility of the EMF implementation and for the environmental performance of the program would rest with the Government of Sindh (Education & Literacy Department/Reform Support Unit). ELD/RSU would among its staff nominate an Environmental Coordinator (EC) who would be the focal point for all matters relating to the environmental issues during the program. The implementation of the EMF in the field will be the responsibility of the IPs/TOP Partner Districts, who would, in coordination and under the supervision of EC, ensure compliance to the environmental guidelines presented later in the document.

4.3 Roles and ResponsibilitiesRSU/ELD Environmental Coordinator (EC): The EC will be overall responsible for the environmental performance of the program, and will facilitate compliance to the EMF and the environmental guidelines presented in this document. The EC will coordinate with the IPs/TOP Districts, Third Party Construction Supervision Firm, , Civil Works Contractors, SEF and the community for the implementation of the EMF and other environmental management activities. The EC will also coordinate with other stakeholders, such as the education department, SEPA or any NGO, as and when required.

TOP District Governments: The IP (District Governments) will be responsible for the on-site implementation of the EMF and the guidelines provided in it. The IP site engineers, District’s EDO Works, and the engineers from the third party construction supervision firm will supervise the school construction/rehabilitation activities, and will ensure that the environmental issues are adequately addressed.

The roles and responsibilities are tabulated in Exhibit 4.1.

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4.4 Environmental Guidelines The guidelines are the key component of the EMF. These guidelines list all the potential effects of each activity of the program and their associated mitigation measures. These guidelines should be followed during the design, construction and operation of the schools. The guidelines are presented in Exhibits 4.2 to 4.4.

4.5 Environment, Safety, Public Health and Hygiene Trainings

Environmental, public health and hygiene trainings will help enhance the awareness level of the IP/SEF staff, district/provincial governments, SMCs and the community on all matters relating to the environment. These trainings will ensure that the requirements of the EMF are clearly understood and followed by the ELD/RSU, IPs/TOP Districts, SEF and community throughout the program period.

The primary responsibility for providing trainings to all program personnel will be that of the ELD/RSU and SEF. The environmental training program will be finalized before the commencement of the design of school buildings. The training will be provided to the ELD/RSU staff, IPs/TOP District EDO - Works, Third Party Construction Supervision Firm nominee, and the community.

The scope of the training will cover general environmental awareness, safety aspects, public health, hygiene, waste disposal and effective house-keeping during the construction activities, in order to minimize the environmental concerns of the program.

The training modules for SMCs and communities will be prepared and conducted in English, Sindhi and Urdu.

The first training and dissemination activity under the program is planned to be carried out by the end of April 2009, in a workshop to be held in Karachi to discuss the results of the analytical work done by the two consultants hired by the Bank (environmental geologist, and structural engineer). This workshop will address the water contamination and safety issues, and will be attended by, among others, key technical personnel from the Districts, Works and Services Department, and RSU. It is estimated that about 50 persons will attend the workshop.

4.6 Documentation and Reporting MechanismRSU/ELD and SEF will be responsible for developing reporting mechanism for ascertaining compliance to the requirements of EMF guidelines.

The RSU/ELD will have the prime responsibility for generating various documents and maintaining the records. ELD/RSU will develop easy-to-fill checklists, on the basis of the environmental guidelines discussed above. The site engineer (EDO - Works) in each IP in the case of TOP districts, and visiting monitoring/authorized officer in the case of SEF, will fill in the checklist during his/her site visit to the school.

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The IPs (supervisory site engineer from Education Works) will be required to fill these checklists and provide a copy to the Third Party Construction Supervision Firm, who will maintain a complete record of these filled checklists and any follow-up action required/taken on them. In the case of the PPP Schools, SEF will be responsible for maintenance of all such records as well as follow up action.

RSU/ELD will also maintain a complete record of the training modules developed, training programs conducted and the attendees of these trainings.

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Exhibit 4.3: Roles and Responsibilities

Organization Responsibility

RSU/ELD (through the Environmental Coordinator-EC)

Overall responsible for the implementation of the EMF and the environmental performance of the program.

Develop environmental, public health, safety and hygiene training modules and periodically conduct/organize these trainings for the IPs, PPP-SEF staff, teachers and the SMC/community.

Maintain a complete record of the trainings (training modules developed, trainings conducted and attendees)

Prepare simple checklists on the basis of the environmental guidelines (Exhibits 4.2 to 4.4)

Ensure that the concerned District and IPs officials fill the checklists for each construction or rehabilitation works on a regular basis.

Ensure that the Secretary to SMC of each school/Site Engineer (Education Works) fills the checklists on periodic basis.

Ensure that the Third Party/Site Engineer or authorized person or any Monitoring Officer fills out the checklists and determines and/or report any corrective action, if required.

Ensure that the IPs (education works/schools/third party) maintain a record of all the filled checklists, and the corrective actions planned/undertaken either themselves or through the third party engineering consultant firm.

Review the filled checklists and determine any corrective action, if required.

Maintain a record of all the filled checklists, and the corrective actions planned/undertaken.

Periodically visit the schools/construction sites, in coordination with the third party construction supervision firm in order to monitor the reliability of filled checklists, and to determine their effectiveness.

Maintain a complete record of the above mentioned field visits.

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Organization Responsibility

Ensure through the third party engineering consultant firm/site engineer (education works) that the environmental considerations for the school building design are adequately adhered (Exhibit 4.2).

Coordinate with any other stakeholder, such as the Education Department, SEPA, or any NGO or any other organization interested to know the environmental performance of the program.

IPs/TOP Districts/SMCs and PPP-School Head Masters/Entrepreneurs

Participate in the environmental trainings conducted by RSU/ELD.

Implement the environmental guidelines in the field, during the construction/ operation of the schools.

Fill the environmental checklists on regular/periodic basis, and provide copy to the RSU/ELD EC and PPP-SEF Project Director.

Provide feedback to RSU/ELD and SEF on the effectiveness of the checklists and the EMF.

Contribute to increase the environmental awareness among the community/SMCs.

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Exhibit 4.4: Preliminary Guidelines for the Design Phase4

Design of the school building should adhere to all existing standard technical requirements.

The design should consider the earthquake classification of the area, as well as, the flood risks in the area. In particular, school siting should avoid known seismic fault lines and flood plains.

Use of the local materials should be maximized (when considered feasible and cost effective).

The design should take into account (when feasible, and cost effective), the available skills of the community, in order to maximize local employment.

The design should include provision of safe water supply and adequate sanitation services.

The new school designs should consider the local climate conditions (insulation, predominant wind direction and intensity, temperature, etc.), to maximize the energy efficiency of school buildings in order to reduce the need of costly artificial ventilation and illumination.

In the design of new schools and rehabilitation of existing schools located in off-grid areas, the designer should investigate the feasibility of the installation of low-cost renewable power systems.

The toilet design should address the needs of the children (particularly girls) and teachers, and be water efficient.

In case of the girls’ schools, the boundary walls should be of appropriate height, in line with the local customs and values.

The building should have separate toilets for men and women in a number that is adequate to school enrollment.

4 These guidelines should be considered preliminary and temporary, and will be reviewed and complemented by the work that will be carried out by the two consultants being hired by the World Bank (environmental geologist and structural engineer).

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Exhibit 4.5: Preliminary Guidelines for the Siting and Construction Phase5

School Location

The location should be selected with full consent of the community.

The school building should not be constructed over any disputed land, known seismic fault lines, flood plain, or areas with poor soil support capacity.

The protected areas (the wildlife protected areas, as well as the notified areas of archeological, cultural or historical significance) in the Province should be avoided, when selecting the site for the school (see Exhibits 1.2 and 1.3 for these areas in the Province).

The school should not be constructed on areas having any significant natural vegetation or over cultivated land. When this is inevitable, adequate measures should be taken to minimize the area that needs to be cleared for the building.

Land Acquisition

In the case of public schools, the title of the land should be regularized (registered by the Land Registrar), and formally transferred to the concerned District.

Required documentation should be completed for the land acquisition. These would include preparation of a transfer deed on court papers (Stamp Paper) which should be signed by the owner(s) of the land and endorsed by the Patwari (land record clerk). The transfer deed should then be registered by the Registrar. Involvement of the District Government is also recommended in this process.

Waste Disposal

Appropriate waste disposal measures should be adopted during the construction phase. The construction waste must be disposed in a manner that does not contaminate the soils or water resources (surface/groundwater).

The recyclable waste should be sold to the recycling contractors; the biodegradable waste should be buried at an appropriate site; the left-over construction materials should be sold to other users; and the remaining waste should be burnt at a place at a safe distance from any human settlements.

5 These guidelines should be considered preliminary and temporary, and will be reviewed and complemented by the work that will be carried out by the two consultants being hired by the World Bank (environmental geologist and structural engineer).

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Exhibit 4.6: Guidelines for the Operation Phase

Health and Safety Concerns

The water supply at the schools should be properly treated to ensure its safety for human consumption. A water quality monitoring program should be implemented to ensure long term quality of the water supply system.

The toilets should be kept clean and functional all the time.

Sewage treatment and disposal facilities should be properly operated and maintained in order to prevent diseases and contamination.

Solid waste should be collected and properly disposed.

Awareness level should be raised among the students, teachers and other school staff regarding personal hygiene, water contamination, communicable diseases and the associated precautionary measures.

Awareness level should be raised among the students, teachers and other school staff about precautionary measures that must be taken during natural disasters and other emergencies.

Gender Issues

Separate toilets should be available all times for boys and girls.

Awareness level should be developed on gender issues among the teachers, students and other staff of the school.

General Issues

Environmental awareness should be enhanced among the students, teachers and other staff through various means, including trainings, instructional materials and wall charts.

Attempts should be made to raise the environmental awareness of the community in general, particularly on issues such as waste disposal.

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Sindh Education Reform Program (SERP)

5 Social Management Framework5.1 Social Safeguards 5.1.1 Program Background.

Despite being the province with the highest per capita income in Pakistan, urban rural and gender inequalities in social indicators (particularly in rural areas) are among the highest in Sindh. Improving education outcomes in Sindh is essential for poverty reduction and human development outcomes. The Pakistan National Education Policy prioritizes achievement Education for All (EFA) goals of universal primary enrollment; The SERP assists the provincial and federal governments in their efforts to accelerate progress towards the achievement of its MDG for universal primary education, including removing urban-rural and gender imbalances, as well as enhancing the quality of education and student learning at all levels. The SERP seeks to improve access, equity and quality in education by improving governance and institutionalizing accountability in education service delivery. It combines interventions in the education sector with broader fiscal, financial management and governance reform. The focus is on improving educational outcomes especially among the most vulnerable segments of the population (rural areas, girls) to ensure that growth is inclusive and contributes to poverty reduction.

5.1.2 Program’s of Civil Works

The project has two components that would involve civil works. One is the Terms of Partnership with the Districts (TOP) and the other is the Private Public Partnership Program (PPP). The TOP is an on-going government program. The provincial and district governments will continue to enter into partnership agreements on an annual basis, with conditional grants for school rehabilitation works transferred to district governments based on these agreements. The project will support the program, providing each district with annual performance grant for providing classrooms for shelter-less schools, expanding seating space and putting in missing facilities at existing local schools in order to bring them to minimum infrastructural functionality [Refer Minimum Service Standards, TOP Agreement FY 2008-09]. Fund allocation will be tied to performance to be measured against indicators to be agreed annually under the Terms of Partnerships between the provincial and district governments.

GoS has developed and has begun to implement an innovative public-private partnership (PPP) pilot program. The program is designed to reach rural and poor children and aims to increase school participation particularly of girls. It offers a per student subsidy to private entrepreneurs for each child they enroll in targeted underserved rural localities. Beginning with up to 200 schools in the Financial Year 2008-09, over a period of two years, the program expects to support private entrepreneurs to set up and operate up to 1,000 primary schools in rural under- served communities where alternative schooling options are unavailable. The program will be administered by Sindh Education Foundation. Proposals from voluntary participating entrepreneurs will be evaluated against established criteria and their performance will be monitored and evaluated through the program implementation.

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Sindh Education Reform Program (SERP)

The contract agreement with private entrepreneurs (PPP schools) and with the civil works contractors (TOP schools) will include a declaration that they will follow the ESMF guidelines in the establishment and operations of the schools.

5.1.3 Possible Land Needs and Approach to Address Them

The Project does not require any acquisition of land for the purpose of these two components. The Land Acquisition Act in Pakistan and World Bank OP 4.12 on Involuntary Resettlement are not triggered under the project.

Under the PPP program, the voluntary participating entrepreneurs will be responsible for the establishment and operation of the schools. They will locate the sites of the new schools, obtain access to structures and prepare them for school rooms. They will then submit their proposal for consideration under the program. Public consultations and experiences from existing operations show that new schools, mostly of small size, are established through using self-owned or renting existing structures. Building new schools for this purpose seldom happens. Where such rare situation arises, the new schools will be constructed on public and community lands as agreed with local communities, or leased lands from local people. Some entrepreneurs might also turn to commercial transactions in the land market. This aspect is already built into the initial evaluation survey.

The TOP- based program with districts mainly supports provision of missing facilities and limited school rehabilitation in existing schools. Building rooms for shelter-less schools in the underserved areas is expected to be a very small portion of the program. Given the design of the program and the small size of the facilities, the land needs if necessary will be resolved through using existing public lands or community and private donations. In case of donations, in order to ensure a transparent process, non-pressuring environment and its voluntary nature, documentation of the donation process will be prepared to record at least the following:

(i) The ownership of the land and evidence indicating the voluntary nature of the donation;

(ii) Appropriateness of the donation for the intended purpose; (iii) Economic status of the donor that he/she is above the poverty line or

whose remaining holdings are economically viable; (iv) No encumbrances on the land; (v) No negative livelihood impact on any vulnerable groups; (vi) No compensation to be paid, and (vii) That the owner gives up all claims on the land and the title will be

transferred to the recipient through procedure prescribed by the law of the state.

The documentations will be prepared along the school proposal and reviewed by the district governments for inclusion of the proposal in the district annual plan. The documentation as part of the proposal will be filed at district government for regular monitoring and supervision teams to check for compliance with this framework.. They will also be submitted to the Project RSU and the World Bank.

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Sindh Education Reform Program (SERP)

Grievances related to issues of land donations will be reported and addressed through the existing government system and project management setup. All redress will be carried out at the district level. Since all land-related matters fall under the mandate of the Revenue Department, a District Committee consisting of two Executive District Officers (EDOs) - the Executive District Officer (Education) and the Executive District Officer (Revenue) – will act as the first tier for grievance redress for initial settlement. The second and the final tier of grievances redress will be at the level of the District Coordination Officer (DCO), in case the redress is not provided at the first tier of redress. The Education and Literacy Department will only monitor and review the progress on the issue on a regular basis for its amicable settlement at district level. As under the law of the State, all citizens have the right and access to refer their grievances of land-related matters to court. All grievances filed will be recorded in writing under the project both at the district and provincial level. The monitoring and evaluation teams will also serve as a channel for facilitating grievance redress.

5.1.4 Monitoring of possible land needs

The project has designed a robust monitoring and evaluation system. The project monitoring setup, consisting of third-party monitors, Sindh Education Foundation Monitoring Team and the Impact Evaluation Team, will review and evaluate proposals for project candidate activities for inclusion and financing under the project, as well as monitor and evaluate their implementation performance. Even though the project will not trigger World Bank OP 4.12 on Involuntary Resettlement and the Land Acquisition Act in Pakistan, the monitoring and evaluation teams would cover land-related aspects in their upfront evaluation of candidate proposals and monitoring of the progress of the proposed civil works. The monitoring and evaluation reports will also document their findings and assessment.

5.1.5 Indigenous peoples

It is indicated through operational experiences and extensive planning exercises that there are no indigenous groups as defined under the World Bank Policy OP.4.10. This is also confirmed through public consultations and field visits. Therefore the project as designed is not triggering World Bank Policy 4.10 on Indigenous Peoples. However, screening should continue of project interventions during implementation. In the eventuality that such groups are identified, an Indigenous Peoples Development Plan should be developed to include actions to mitigate possible impacts and ensure culturally appropriate benefits to these people.

5.2 Social AssessmentThe SERP design is developed on a good understanding of the education sector status in Sindh Province, the challenges, various barriers and factors impacting access to quality education. This understanding comes from years of planning and operational experiences as well as academic studies, professional researches and broad feedback from the public. Two major public consultation workshops were held as part of the project preparation to brainstorm over the above issues and design a way forward to address them. A programmatic social assessment is planned under

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Sindh Education Reform Program (SERP)

the project along the annual programming and implementation of various components. It would focus on the following,

Facilitating continuous stake holder consultations through component programming and implementation, particularly with local communities, students and teachers over their respective difficulties and needs in access to better education, and their prioritization in terms of education facilities and services. These would feed back into the project component design and implementation.

Assessing how various constraining factors relating to education (social, political, cultural, economic etc,) are evolving under the project interventions under all components and whether the designed interventions are effective in addressing these factors and improving access to quality education. A better gauging of these would help improve project interventions.

Particular attention to be given to gender dimensions to all component programs. These will cover measures to improve access to and quality education for girls, such as the stipends programs under PPP, and component programs targeting female teachers. The social assessment will also reflect gender perspectives in all project programs.

Screening of possible social safeguard issues. Review of possible land needs for interventions under the PPP and TOP program and making sure that the ESMF is followed in situations of such needs. All project interventions should be screened for possible impacts on indigenous peoples.

The project has designed an elaborate and vigorous M&E system for timely and reliable information on the performance of the SERP components. It will employ both qualitative and quantitative process evaluations, which will be used to both inform and assess modifications in SERP design and implementation. This system consists of many initiatives aligned with component programs and is supported DLI EEP and TA. The M&E will be conducted by the RSU and independent research organizations.

The programmatic social assessment is designed to continue throughout project implementation. This process will be built into the elaborate monitoring and evaluation systems that have been planned along various component initiatives under the four pillars. The TORs and designs are yet to be developed for the component M&E initiatives. The social analysis will be integrated, reflecting largely in the scope of work and methodologies. Each component M&E may vary in terms of its coverage, depth of analysis and methodology for social analysis due to its program focus and design. The following are the generic focus areas across all components.

The social assessment will facilitate continuation of stakeholder analysis and their participation in the project implementation. The project design is anchored on identification of key stakeholders and a good understanding of their respective roles in the reform agenda. Main stakeholders include government institutions, non-governmental organizations, research institutions and other social groups/beneficiaries at all levels of intervention. Their participation is structured into the design of the project programs. The social assessment will monitor and evaluate their participation and roles they play in all project components. It would also facilitate their participation

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through the M&E exercise and provide recommendations for improvement. Special attention will be given vulnerable and disadvantaged groups.

The social analysis will monitor and explore various factors underpinning educational outcomes. It will maintain a focus on factors that continue to impact on access to education, with special attention to the most vulnerable, disadvantaged groups and the most lagging areas. Since the M&E will be tailored on a component program basis, each M&E exercise may have different sets of social factors to be analyzed due to its program focus. These factors will be assessed under the program interventions for their evolving impacts on education and the effectiveness of project interventions to harness their impacts.

The gender analysis will be an important dimension of M&E in all component programs. First, it will assess the performance of the stipend programs for girls, including before and after project comparisons as well as project and non-project school performance comparisons with respect to enrolment and completion rates of female students. Secondly, all analytical data to be collected should be disaggregated by gender to enable a gender dimension of the analysis and bring out the view points of social groups, particularly women.

The social assessment should include a social safeguard analysis. Though these impacts, such as land acquisition and impacts on indigenous groups, are not unanticipated under the program as designed, it will be necessary to continue screening of project interventions, particularly under the PPP and TOP programs. In the eventually of such unanticipated impacts, the social assessment should recommend follow actions to address them in line with relevant local laws and World Bank policies.

The RSU will assume the responsibility for M&E under the SERP. It will develop the TORs, design the M&E for component programs and establish the M&E teams. It will recruit dedicated teams under the SERP component. The teams could be established within the government or outsourced. There would be also independent researchers joining the M&E programs.

The social assessment will use a range of tools for data collection and analysis. The project will establish a series of surveys as process monitoring, to monitor and evaluate the project implementation progress. These tools will be complement and blend into the M&E design as appropriate. The RSU will regularly gather information and report on the implementation of SERP components. The information will be regularly collected and maintained in a database. Additionally the social assessment will also use questionnaire surveys, focus group discussions and interviews of key informants. Where possible, participatory rural appraisal tools should be designed into the M&E initiatives such as social group mapping in conjunction with access to education, ranking of problems regarding access and quality of education. These should enable a combination of both qualitative and quantitative analysis.

Choice of social assessment tools will depend on the component activity needs. As part of the design of the component program, RSU will also develop the TOR for the planned M&E and recruit qualified candidate for this assignment. The TOR will

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incorporate the social analysis into the M&E design. The World Bank will also review the TORs and provide its input.

The project is expected to generate a significant amount of information during implementation. These will be summarized and submitted to the relevant parties mostly in the form of progress monitoring reports for both project output and outcome.

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Sindh Education Reform Program (SERP)

6 Conclusions SERP’s School Rehabilitation Program (SRP) Component involves physical interventions during its tenure. Each year of the program is expected to fund the school building construction/rehabilitation in all 23 districts of Sindh province of Pakistan. The proposed school locations being spread all over the province, and the magnitude of the individual construction works for addition/expansion of existing school building or provision of new ones, will be quite small, thus causing minimal of the environmental impacts, and even these impacts will be mostly temporary in nature.

In order to assess the above impacts, an environmental assessment of the proposed program was carried out which confirmed that the program would not result in any significant and lasting environmental impacts. It was also concluded that the present assessment was sufficient, and no further EA action would be needed, in accordance with the national regulatory requirements as well as WB OP 4.01.

In order to address the potentially adverse impacts of the program, particularly during the school construction, an ESMF has been developed, which will further improve the environmental performance of the program in Sindh.

In addition to the analysis of the potential adverse impacts, the assessment addressed important issues that are likely to affect the long term development effectiveness and sustainability of the program. Examples of such issues are:

(i) The existing contamination of the drinking water sources for a significant number of schools;

(ii) The vulnerability of school buildings to natural disasters;

(iii) Insufficient awareness at the top levels of the GoS regarding the risks and potential consequences of natural disasters;

(iv) Energy efficiency aspects in the design of new schools; and

(v) Feasibility of the installation of low-cost renewable power systems in schools located in off-grid areas.

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Sindh Education Reform Program (SERP)

ANNEX 1

Sindh Education Reform ProgramEnvironmental, Safety and Safeguards Aspects

Implementation Strategy

Activity

Implementation Schedule

Bank Analytical WorkMay 15 2009

Year 1 March 31 2010

Year 2March 31 2011

Year 3March 31 2012

Mapping of areas with high risk of natural disasters (earthquakes, floods, landslides, etc.), and arsenic and fluoride water contamination.

Preliminary mapping of earthquake, flood, and water quality risks prepared by two consultants hired by the Bank based on existing maps (*) (A Structural Engineer and an Env. Geologist).

(*) Seismic Map for Pakistan (Geological Survey of Pakistan).

Note: The National Disaster Management Authority (NDMA) is currently working to complement and update existing national maps.

Updated maps for Sindh based on results of work being done by the NDMA are available.

Inspection of existing schools in high risk areas.

Preliminary inspection of schools located in areas of Sindh province classified as zone 4 and 3 (*).

Drinking water testing in the schools inspected (i.e., arsenic levels, coliforms, etc.). To be carried out by consultants hired by the Bank.

Preparation of a list of priorities. Priorities include

Detailed inspection of the remaining schools in high risk areas including testing of materials when deemed necessary (About 400 schools).

Preparation of a second list of priorities. Priorities include damaged schools, schools with inadequate structure or foundations, schools built in fault lines, and high levels of water contamination. (To be done by the third party construction supervision firm).

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Sindh Education Reform Program (SERP)

Sindh Education Reform ProgramEnvironmental, Safety and Safeguards Aspects

Implementation Strategy

Activity

Implementation Schedule

Bank Analytical WorkMay 15 2009

Year 1 March 31 2010

Year 2March 31 2011

Year 3March 31 2012

damaged schools, schools with inadequate structure or foundations, schools built on top of fault lines, high levels of water contamination, etc.

(*) About 200 schoolsReinforcement of vulnerable schools included in the priorities listed above

Preparation of designs for reinforcement of vulnerable schools in high risk areas. To be done by the third party construction supervision firm. The allocation of TOP funds should give priority to this activity.

Implementation of a Pilot Project with TOP funds aimed at reinforcing the most vulnerable schools identified in the inspections (about 10-15 schools).

Implementation of reinforcement program (*) according to degree of priority (starting at top of priority list).

Compliance is certified by Supervision Consulting firm.

(*) About 100 schools

Implementation of reinforcement program (*).

Compliance is certified by Supervision Consulting firm.

(*) About 300 schools

Guidelines for school Preliminary guidelines and Inclusion of the preliminary Inclusion of the final No TOP funded

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Sindh Education Reform Program (SERP)

Sindh Education Reform ProgramEnvironmental, Safety and Safeguards Aspects

Implementation Strategy

Activity

Implementation Schedule

Bank Analytical WorkMay 15 2009

Year 1 March 31 2010

Year 2March 31 2011

Year 3March 31 2012

siting, and specifications for design and construction, including safety aspects, and drinking water and sanitation facilities. Sanitation facilities should be adequate for girls.

specification prepared by the two consultants hired by the Bank.

guidelines in the Works and Services department existing procedures.

Inclusion of the preliminary specifications in all bidding documents issued by the Works and Services department for school construction, improvement or rehabilitation which are to be carried out before March 2010.

Review of the preliminary guidelines and preparation of the final siting guidelines and specifications for design and construction, based on Pakistan’s Building Code - 2007 (in process of approval). To be done by the third party construction supervision firm.

Creation of a Technical Panel conformed by the Sindh government officials to review the work carried out by the consulting firm.

guidelines (*) in the Public Works department existing procedures.

Inclusion of the final specifications in all bidding documents for school construction, improvement or rehabilitation.

(*) To be done by the third party construction supervision firm.

construction should be done without complying with the final guidelines and specifications.

Compliance is certified by Supervision Consulting firm.

Model designs for schools that would

Model architectural and structural designs (about 5-6), done by the third

Adoption of the models designs by the Education

All new schools should be built using

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Sindh Education Reform Program (SERP)

Sindh Education Reform ProgramEnvironmental, Safety and Safeguards Aspects

Implementation Strategy

Activity

Implementation Schedule

Bank Analytical WorkMay 15 2009

Year 1 March 31 2010

Year 2March 31 2011

Year 3March 31 2012

be: - Energy efficient- Structurally safe- Cost effective- Well built- Appealing to students.

party construction supervision firm.

Review of the consulting firm’s proposals by the Technical Panel mentioned above.

and Public Works departments.

the model designs.

Compliance is certified by third party construction supervision firm.

Third party construction supervision firm for quality control.

Hiring( TA funds) of a third party construction supervision firm to supervise the construction of schools, ensure compliance with siting guideline, design and construction specifications, and EMF requirements.

Water quality testing with priority given to those located in the areas with geological structures prone to the contamination with arsenic and fluoride.

Preliminary identification of contaminated areas by the consultants hired by the Bank.

Testing of the drinking water in about 200 schools according to priorities listed above.

Carry out a complementary water testing program of about 400 schools in the areas defined previously. Should include arsenic and fluoride levels and total coli forms.

Recommendation of cost effective methods for arsenic, fluoride removal and for disinfection. (to be done by a specialized consulting firm hired using TA funds).

Install treatment facilities in all affected schools giving priority allocation from TOP program funds.

Compliance is certified by third party construction supervision firm.

Carry out a water quality monitoring program in all schools built, improved, or rehabilitated by the Program for insuring the safety of drinking water (to be done by a specialized consulting firm). Main parameters to be monitored: arsenic

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Sindh Education Reform Program (SERP)

Sindh Education Reform ProgramEnvironmental, Safety and Safeguards Aspects

Implementation Strategy

Activity

Implementation Schedule

Bank Analytical WorkMay 15 2009

Year 1 March 31 2010

Year 2March 31 2011

Year 3March 31 2012

concentration, and total coliforms.

Arsenic concentration must be lower than 0.05 mg/liter and total coliforms must be absent. Frequency should be at least once a year.

Renewable power supply in schools

Preparation of TORs for hiring consultants to identify and assess cost effective and feasible technologies for renewable power supply systems.

Identification and evaluation of cost effective technologies that are applicable to Sindh schools including the operation and maintenance aspects. Identification of schools that should be included in a Pilot Program. To be done by consultants hired with TA funds.

Design of a Pilot Program for the installation of renewable power systems in 10-15 selected schools. To be done by consultants hired with TA funds.

Implementation of the Pilot Program in selected schools.

Compliance is certified by Supervision Consulting firm.

Certification by the supervision firm, that the power systems installed are working properly.

Preparation of a comprehensive program developed for upscaling the Pilot Program including prioritization of funding from TOP. For each project, compare the costs of renewable systems with the costs of connection to the nearest power grid.

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Sindh Education Reform Program (SERP)

Sindh Education Reform ProgramEnvironmental, Safety and Safeguards Aspects

Implementation Strategy

Activity

Implementation Schedule

Bank Analytical WorkMay 15 2009

Year 1 March 31 2010

Year 2March 31 2011

Year 3March 31 2012

Injury and fatality prevention in natural disasters.

Design of a training program for teachers and head teachers in schools located in high risk areas. (To be done by consultants hired with TA funds).

Implementation of the teacher and head teacher training program. Teachers will train children in their schools.

All children in schools located in high risk areas must have been trained in injury and fatality prevention during natural disasters.

Geographical Information System

Preparation of TORs for assessment of needs and specification of the software and hardware required.

Assessment of needs, design of the most appropriate system, and preparation of specifications for software and hardware purchase. To be done by an individual consultant hired with funds from TA.

Acquisition of required hardware and software.

Data collection & digitalization. Development of a fully operational GIS System.

Training of key personnel.

Capacity Building Preparation of TORs for training and capacity building of GoS technical officials in natural disaster management, water quality management, design and construction specifications.

Design a capacity building program covering the mentioned issues. Train about 50% of the required personnel.

Workshop in Karachi for about 50 technical persons from GoS to present and discuss results of the work carried out by the two Bank consultants regarding natural disasters and water quality.

Train the remaining fraction of the required personnel.

Contamination Preparation of an Implement the Certification by third

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Sindh Education Reform Program (SERP)

Sindh Education Reform ProgramEnvironmental, Safety and Safeguards Aspects

Implementation Strategy

Activity

Implementation Schedule

Bank Analytical WorkMay 15 2009

Year 1 March 31 2010

Year 2March 31 2011

Year 3March 31 2012

prevention, and optimization of use of natural resources

Environmental Management Framework with guidelines to ensure contamination resulting from activities such as school construction and operation.

recommendations specified in the Safeguards Framework.

party construction supervision firm that all recommendations of the ESMF have been implemented.

Environmental Assessment and Environmental and Social Management Framework A-7


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