Design & Implementation: Safeguards

June 6, 2013


World Bank safeguard policies are designed to prevent and mitigate undue harm to people and their environment in the development process. As the Bank's environmental and social agendas have evolved, its safeguard policies have also shifted from focusing on mitigating the potential environmental and social damage toward a more comprehensive focus on sustainability of projects (a shift from do no harm towards do good). As such, the Bank's social and environmental safeguard policies seek to ensure that relevant measures, capacities and processes are in place, and that their application helps Bank's borrowers decide what actions and programs need to be taken to ensure the environmental and social soundness of projects. Safeguard policies also provide a platform for the participation of stakeholders in project design and selection, and have been an important instrument for building ownership among local populations.

Community-driven development (CDD) projects are characterized by wholesale implementation of many smaller subprojects across numerous sectors with no ex-ante knowledge of the precise nature of the projects. A significant challenge in ensuring environmental and social sustainability in CDD projects is the fact that the location and design of the eventual subprojects are not known at project appraisal, though the types of potential subprojects may be fairly well-defined. As a result, traditional safeguards instruments (e.g. an environmental assessment or resettlement action plan) cannot be prepared before appraisal, and safeguards measures to support environmental and social sustainability can only be established during project implementation. Most CDD projects use the framework approach which been referred to in recent years as environmental and social management framework (ESMF) for meeting World Bank safeguard requirements.

Unlike standard investment projects, where the Bank finances specific investments, the projects that use frameworks are more programmatic in nature, with an emphasis on gradually building the capacities of implementers. The framework approach also requires greater prescription for screening and mitigation measures by the sponsor and implementers to ensure subprojects are environmentally sustainable and that resettlement frameworks are followed. Another challenge is undertaking viable monitoring/or auditing for a multitude of small scale and geographically dispersed subprojects.

CDD projects are often associated with fast tracking the appraisal process and/or support a wide range of potential infrastructure subprojects for funding that have not been thoroughly designed and appraised before Board approval. Some Category B CDD projects include possible Category A subprojects that can be financed but only after a no objection is given from the Bank as stipulated in the Legal Agreements. In these circumstances, it is still the obligation of the borrower to ensure safeguards are applied. When such frameworks are applied to Category A subprojects, there is likely a greater safeguard and associated reputational risk (refer to "Key Characteristics of CDD Projects in Relation to Safeguards" below for listing of safeguards challenges with CDD projects).

Key Characteristics of CDD Projects in Relation to Safeguards

  • The use of frameworks covers a wide range of sectors and subproject types across both Category A and B projects.
  • Many CDD projects are rural, decentralized, locally implemented civil works and livelihoods activities in which regional executing units, communities, or groups of beneficiaries are responsible for choosing and assuming operations and maintenance (O&M) of the subproject.
  • These subprojects (across the entire portfolio) number in the tens of thousands and benefit millions
  • On the average, subproject costs are small ($1,000-50,000) with no or minimal environmental impacts but there still is a need to sample a subset of schemes to assess safeguard performance.
  • Efforts are being made at the grassroots level to achieve a high degree of awareness concerning environmental issues across layers of executing agencies and beneficiaries.
  • In a country lending portfolio, numerous projects use frameworks and there is a growing collection of these products being used across similar rural infrastructure activities, including water supply systems, irrigation, farm-to-market roads, livelihoods, and watershed management.
  • Many countries are implementing repeater projects and use the same safeguard approaches without verifying results.
  • There are limited efforts to develop safeguard performance lessons learned within countries.

Specific guidance on the preparation of safeguard provisions for CDD projects has unfortunately been limited over the past decade, and the existing OP/BPs do not easily transpose into operationally oriented provisions to apply the Bank safeguard policies. With the proliferation of CDD type projects across the Bank over the past 10 years, the operational safeguard aspects of these projects are now coming under greater attention as these have an impact on project design, supervision and risk management of the Banks portfolio. Connected to these issues is the growing interest in determining the quality of safeguard performance across the Bank CDD portfolio.