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AFTES Working Paper No.2 Environmentally Sustainable Development Division Environmental Policy and Planning 20361 ENVIRONMENT IN THE AFRICA REGION PORTFOLIO Leif E. Christoffersen and Lee Talbot January 1994 Environmentally Sustainable Development Division Africa Technical Department The World Bank Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized

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Page 1: World Bank Documentdocuments.worldbank.org/curated/en/554161468210860118/pdf/mul… · environmental management. Several infrastructure projects were also designed to meet major environmental

AFTES Working Paper No.2Environmentally Sustainable

Development Division Environmental Policy and Planning

20361ENVIRONMENT INTHE AFRICA REGION PORTFOLIO

Leif E. Christoffersen and Lee Talbot

January 1994

Environmentally Sustainable Development DivisionAfrica Technical DepartmentThe World Bank

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ENVIRONMENTin the

AFRICA REGION PORTFOLIO

A REPORT

by

Leif E. Christoffersen and Lee M. Talbot

January 1994

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CONTENTS

Foreword.....v

I. INTRODUCTION..... 1

II. MAJOR ENVIRONMENTAL PROJECTS APPROVED DURING FY88-92.....2

a) The Project Sample.....3

b) Cofinancers and Coordination.....4

c) Heavy Reliance on Loan/Credit Covenants.....5

d) Complexity Compounded by Implementation Agencies not Participatingin Loan/Credit Negotiations.....5

e) Number of Project Components or Disbursements Categories.....6

f) Supervision Missions and Environmental Expertise.....7

g) Institutional and Coordination Issue in Environmental Project Work.....9

h) Performance Ratings................10

i) Sustainability Issues.....11

III. GLOBAL ENVIRONMENTAL FACILITY.....12

IV. ENVIRONMENTAL ASSESSMENTS.....14

V. CONCLUSIONS...........17

VI. RECOMMENDATIONS.....19

Annex: Resettlement.....23

111

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Foreword

As World Bank involvement in environmental management and conservation broadens andmatures, implementation will take center stage.

This review of the Environmental Portfolio in the Africa Region was prepared by twoSenior Consultants-Leif E. Christoffersen and Lee M. Talbot-as background for the1993 Annual Review of Project Peformance (ARPP). The initial findings of theresettlement review for the Africa Region, coordinated by Cynthia Cook, Principal SocialScientist, AFTES, are summarized in the annex. Urban environmental issues werereviewed under the infrastructure section of the ARPP.

The review focuses on the small but fast growing group of projects which haveenvironmental planning and conservation as their primary goal. It also reviews the GEFprojects which are just getting underway as well as the implementation of mitigationmeasures agreed to under environmental assessments (EA).

Most elements of the Africa Region environmental portfolio are at the initiation stage andhave yet to face the test of implementation and yield sustainable results on the ground. It isclear that environmental management projects have many of the characteristics whichmake implementation difficult and, therefore, call for careful supervision. Environmentalactivities bring into play new and inexperienced institutions, while conflicting donorinterests can lead to coordination problems. Environmental management also calls for ahigh degree of community involvement and requires cooperation among many differentpublic sector institutions and NGOs.

This review tries to reveal early signs of trouble and draw lessons for putting intooperation the National Environmental Action Plans (NEAP) being established in all IDAcountries. Although the focus is on country issues, the review also examines the challengesthe Bank faces in supervising the implementation of its fast growing environmentalportfolio. The main findings of the present review were discussed under the ARPP andintegrated into the Region's action plan. The review is published as an AFTES DivisionalPaper for easy reference by Projects Officers and Managers in the Bank and in otherdevelopment agencies as well as for those responsible for environmental programs inAfrica.

ean H. Doyen, efEnvironmentally Sustainable Development DivisionTechnical DepartmentAfrica Region

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I. Introduction

Environmental issues have been included in recent World Bank Annual Reports onPortfolio Performance (ARPP); but lacking a strong information base, there waslittle on which to base any meaningful analysis. Therefore, the Regional VicePresidency, the Africa Technical Department (AFT), and the EnvironmentallySustainable Development Division (AFTES) management called for a separate re-view of the implementation experiences of environmental lending in the AfricaRegion as an input into this year's Annual Review of Portfolio Performance(ARPP). The resulting review focused on projects with broad environmental con-tent, environmental assessments (EAs), and the Global Environmental Facility(GEF). The review is based on staff interviews, reading of ARPP documentationfrom previous years, project files at Bank Headquarters, and materials gatheredfor the 1993 World Bank Annual Report on Environment.

This kind of review immediately encounters problems of definition be-cause many different approaches might be applied to "environmental lending."Rather than try to define "environmental project," the Bank has pursued a cross-sectoral approach to environment and, unlike many past lending initiatives, has notset specific lending objectives for any separate stream of "environmental lending."Instead, environmental issues are expected to transcend all Bank work, making thetask at hand quite challenging. Ideally, such a review would embrace all the AfricaRegion's lending operations as well as its country and sector work. But because oftime and other constraints, this report limits its focus to a group of projectsidentified as having broad environmental objectives. Their experiences may throwlight on implementation issues affecting the larger Bank "environmental" portfolioin Africa.

The Wapenhans Report and recent ARPP reports

The Wapenhans Report (Effective Implementation: Key to Development Impact,Report of the World Bank's Portfolio Management Task Force)' delivered a power-ful warning about the declining performance of the Bank's overall portfolio. Itnoted that the share of problem projects under execution had almost doubled-from 10 percent in FY79-81 to 17 percent in FY89-91. Moreover, this negativetrend had accelerated over the last three years, and performance problems weremost severe in the Africa Region. The report also referred to major problems be-ing experienced in the Bank's new areas of lending. Among these, environmentwas reported to have the highest (worst) problem ratings score-as much as 30percent of ongoing environmental projects were having major problems.

The Wapenhans Report does not provide data on the regional share of thisoverall 30 percent problem-project reference for environmental projects; nor doesit give much information on how this alarming implementation rating for environ-mental projects was calculated. Considering the exceptionally difficult implemen-

Internal report presented to the World Bank Board of Directors for initial considerationon December 1, 1992 by the World Bank Portfolio Management Task Force.

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Environment in the Africa Region Portfolio

tation problems facing Africa, it is necessary to examine the implementation ex-periences of African projects with major environmental focus.

The last semi-annual ARPP report for Africa Region, dated May 1993,makes no mention of the Wapenhans Report "alert" or, for that matter, any othermajor concern about environmental project implementation in the Africa Region.The question then is whether the Wapenhans Report was mistaken in its high con-cern about environmental project, or if the ARPP process has given inadequateattention to problems facing Bank-funded environmental activities. Related to thisis whether the Africa Region faces fewer implementation problems in this categorythan other Bank Regions. Could it be, as suggested by some staff interviewed, thatenvironmental projects in Africa were less complex than in other regions? Thesequestions cannot be answered without an adequate project-related information baseon which to base a meaningful portfolio analysis of environmental issues inongoing projects. This report will make recommendations towards improving thissituation.

II. Major Environmental Projectsin the Africa Region FY 88-92.

This section looks at 10 projects approved since mid-1988 which emphasize envi-ronment or natural resource management. It examines their latest project perform-ance ratings and addresses four major issues related to project complexity whichthe Wapenhans Report has singled out as potential impediments to effective projectimplementation. These are:

* the number of cofinancers* the number of project components or disbursement categories* excessive reliance on covenants* project complexity compounded by implementing agencies not participating

in loan/credit negotiations.

The discussion also explores some key environmental and institutional is-sues important to the implementation of environmental activities, and examines theobservations on Bank-wide implementation issues in the 1993 World Bank AnnualEnvironment Report. These include weak technical and managerial capacity ofagencies with central environmental responsibilities, institutional deficiencies in theentities responsible for implementing environmental projects and components,insufficient attention to environmental issues during project supervision, and in-adequate performance indicators.

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a) The project sample

At the time of the major reorganization of the Bank's environmental work in 1987,it was wisely decided not to set any lending objective targeted towards a separatestream of new "environmental" projects. The goal was to ensure that en-vironmental concerns were reflected in all areas of lending. Although this funda-mental goal is still upheld, there have always been temptations, coming from bothwithin and outside the Bank, to try to tally "environmental lending" separately,thus undermining the cross-sectoral nature of environmental objectives.

Nonetheless, some specific "environmental" projects have emerged fromnational environmental planning processes, such as NEAPs, with a broad projectfocus on establishing new environmental institutions and strengthening nationalenvironmental management. Several infrastructure projects were also designed tomeet major environmental benefits. Both the national and sectoral projects in thissubgroup include environment in the project title. Another series of agriculturalprojects had wide natural resource management objectives. For the purposes ofthis report, it was decided to cover all projects relating to NEAPs and all infra-structure and agricultural projects with environment or natural resource manage-ment in their titles as well as those focusing on wildlife and national parks. Thecore group of 10 environmental projects selected for this review are those in theAfrica Region's portfolio (approved before the end of FY92) which fall into thesethree subgroups.

During this period, only six projects in Africa carried environment in the projecttitle. They are:

* COTE D'IVOIRE: ABIDJAN ENV. PROTECTION (FY90)* MADAGASCAR: ENVIRONMENT I (FY90)* BURKINA: ENVIRONMENTAL MANAGEMENT (FY91)* MAURITIUS: ENVIRONMENT (FY91)* ANGOLA: LOBITO URBAN ENVIRONM. REHAB. (FY92)* NIGERIA: ENVIRONMENTAL MANAGEMENT (FY92).

Three more projects carried natural resource management in the project title:* CAR: NATURAL RESOURCE MANAGEMENT (FY90)* BENIN: NATURAL RESOURCE MANAGEMENT (FY92)* MALI: NATURAL RESOURCE MANAGEMENT (FY92).

Only one project deals (in this case exclusively) with wildlife and national parks:* KENYA: PROTECTED AREAS AND WILDLIFE SERVICES(PAWS)

(FY92).

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Last year's Africa Region ARPP included a wider realm of "environmentallending" which included ongoing forestry projects in addition to the above threeproject subcategories. The forestry projects are not included in this analysis sincethey are covered in the agricultural sector review under ARPP.

b) Cofinancers and coordination

Cofinancing partners provide obvious advantages to an environmental investmentprogram, but they can also complicate implementation. For example, the majorimplementation problem facing the Kenya Wildlife Services project is caused bydelays in making six cofinancing arrangements effective. During appraisal of theMadagascar Environment project, donor coordination problems were anticipatedamong the nine donors involved in the larger environmental program. To dealwith potential problems, a full-time Multidonor Secretariat was set up at the Bank,funded by one of the cofinancers. Sharing of donor supervision and implementa-tion experiences is part of this coordination. This effort has produced such positiveresults that it is being expanded to cover more countries.

Lessons from the World Bank's Sahelian Department show that continuousdonor consultations throughout the project cycle can ensure effective donor assis-tance in the implementation phase. On the other hand, donor assistance solicitedlate in the project cycle, say, after appraisal, provides less effective results.

The Madagascar and the Mauritius projects are "offsprings" of NEAPS.They are parts of larger environmental investment programs prepared in parallel tothe NEAPS. Both led to Bank-sponsored donor meetings which were consideredsuccessful on two important points-the projects were oversubscribed and theybrought new donors into those countries. However, in the Madagascar andMauritius donor meetings the Bank took a courageous stand. It stated its willing-ness to be "lender of last resort" and thereby promised to pick up whatever ele-ments of the larger program (which the Bank had appraised) that were not fundedby other donors. Most other parts of the investment program were covered byother donors in parallel funding arrangements. Hence, the Bank took the risk thatit might be left with the more difficult program elements to implement. In retro-spect the Bank's Madagascar project seems to suffer from this risk taking. Theactivities of the larger program which are performing well-mostly local privateinstitutions-are funded by other donors. Those left for funding under the Bankproject seem much more difficult to move.

The other seven projects have between zero and three confinancers. Sofar, there are no major implementation problems arising from "cofinancing com-plexities" in projects with few cofinancers. Environmental lending/funding is verypopular with donors, and therefore it is extremely important to establish effectivedonor coordination mechanisms throughout the project cycle before problemsarise.

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Environmental projects can benefit from past mistakes in other areas ofdevelopment assistance caused by conflicting approaches by different donors. Therecent GCA meeting heard a strongly worded plea from African leaders that do-nors do better at coordinating development assistance, particularly in projectpreparation for increased environmental development assistance. Donors must bewilling to fund those projects which are within the framework of an agreed na-tional environmental program. They should also agree to joint modalities for im-plementation assistance. Borrowers, on the other hand, must demonstrate that en-vironmental policies and projects are pursued as part of a genuine national and lo-cal commitment and not because it attracts new development assistance. Amongthe projects reviewed, there are signs of implementation problems because of lossof government interest once new funding is secured.

c) Heavy reliance on loan/credit covenants

Most of the projects resort to considerable loan/credit covenants-and it is hard totell if they are excessive or not. Covenants may be introduced to avoid problemsthat surfaced in the implementation of similar projects elsewhere, or in other pro-jects in that country. The number of covenants itself may be less relevant than thenature or degree of difficulty in meeting the covenants. The slow-movingMadagascar project made an intensive use of covenants-yet it has already met 27of its 31 covenants. Staff interviewed pointed out that the government itself in-sisted on including all interagency agreements as covenants in the CreditAgreement; hence there were more covenants than Bank staff had anticipated. Onthe other hand, projects with many fewer covenants-e.g., some of the natural re-source management projects-have had considerable delays in carrying throughcovenants concerned with major pieces of legislation, such as land tenure reforms.

Differences were noted in the use of effectiveness conditions. TheMauritius project had no conditions of effectiveness and is performing well. TheNigeria project, meanwhile, had a series of conditions which have delayed imple-mentation by almost a year. Whether the latter is connected to the number of loancovenants is unclear, since slow implementation of projects is common in theBank's overall Nigerian portfolio.

d) Complexity compounded by implementation agencies not participatingin loan/credit negotiations.

The key implementation agencies, those mainly responsible for the project, havenot always been present at negotiations. All the projects except the Kenya projectcover many agencies beyond the one with primary responsibility. Although themain implementing ministry and the ministry responsible for Bank-relations(finance, plan, etc.) were usually represented, not all ministries were involved.The Nigeria project was represented by FEPA (Federal Environmental ProtectionAgency) and the Federal Ministry of Finance and Economic Development as wellas the Ministry of Agriculture. The Madagascar project had a particularly broad-

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based negotiating team covering virtually all the implementation agencies. The twoinfrastructure projects had representatives from local government or other localinstitutions present at negotiations. The importance of all implementation agenciesbeing present at negotiations varies with the degree to which important business-e.g., issues not yet fully resolved-is conducted at this late stage. Most projectsseem to have pre-negotiated agreements in the field prior to formal Banknegotiations. In such cases the composition of the negotiating team sent to Bankheadquarters may be less import. As a general rule, representatives of the keynational and, if relevant, local agencies responsible for implementing projectsshould participate at some stage in the loan/credit negotiations.

e) Number of project components or disbursement categories

Three of the projects (Mauritius, Madagascar, and Nigeria) address national envi-ronmental management objectives, covering a broad spectrum of agencies andinstitutions. Madagascar's implementation problems (6 components and 32 sub-components) have been severe ever since the project became effective. In particu-lar, the key public sector institutions under the project (e.g., ONE: the NationalEnvironment Office) are off to a slow start. This is partly due to the adverse politi-cal situation over the last two years, which has caused considerable paralysis inmost ongoing Bank projects. Hence, poorly performing public institutions are notunique to the environment. The Nigeria project (3 major components, 39 sub-components) has been greatly delayed in meeting effectiveness conditions, as havemost projects in the Nigeria portfolio. Since this project has only recently becomeeffective, there has been no basis on which to judge performance. However, thecentral government agency, FEPA, has several characteristics similar to those ofONE in Madagascar: (a) both are new institutions with little operational experi-ence and not much clout in the civil service structure; and (b) their mandates arestill untested and their role in national development policy planning is not yetestablished.

The Madagascar project suffered a setback when, soon after Board ap-proval, ONE was moved from a central point in the government (Planning andEconomic Affairs) to a sectoral ministry (the Ministry of Rural Development).However, it has an advantage over Nigeria in that it possesses a fully articulatednational environmental plan (NEAP) derived through a broad participatory proc-ess. The Madagascar project is linked to good private sector and national NGOs,which are making substantial progress. The Nigeria project puts less emphasis onthe private sector. Of the three projects, the Mauritius project (with six compo-nents) has made the most progress in implementation. Being a more developed,small country with an efficient government structure gives Mauritius an advantageover the other two countries.

The four natural resource projects (CAR, Burkina Faso, Benin, and Mali)are focused on rural areas. They have several common features: they are coordi-nated by agricultural or rural development ministries; they consider cross-sectoral

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activities of key importance; they have decentralized most planning to local gov-ernment levels; they foster considerable local community participation; and theymonitor results. Changes in land tenure legislation, which are also expected, havebeen given critical importance in at least three projects (Benin, Mali, andBurkina). Changes of this kind are essential to the success of each project, but ex-perience also suggests that such change is difficult to implement, even if writteninto loan/credit agreements. It can be assumed that whenever land tenure reformsare required (e.g., the Burkina project) for reaching estimated project benefits,such action should be taken by the government before Board presentation, ratherthan left as a condition of effectiveness or as part of time-bound requirementsduring the supervision phase. However, the experience of the Mali project alsosuggests that, if finding feasible options for these reforms becomes a priority dur-ing supervision, results can be positive at that stage as well.

The Kenya project is the only one in the portfolio which deals explicitlyand solely with wildlife and national parks. Implementation, other than cofinanc-ing, is progressing well. In many ways it has the general characteristics of a clas-sical Bank project: it reinforces and strengthens many ongoing activities; it dealswith a single institution formed from two already existing institutions (the KenyaNational Parks Department and the Game Department); and the single institutionhas a new and broader mandate. The newly merged institution, KWS, has foughtfor a semi-autonomous position but has encountered resistance from some govern-ment ministries. The project has many pioneering features related to its focus onwildlife and a national park system as a development activity. Lessons from thisproject, particularly its efforts to establish an independent or more semi-autono-mous status for a national park system in an African country, would have wideinterest for other parts of Africa concerned with protecting wildlife and promotingtourism.

The Abidjan and Angola projects focus on infrastructure. Both are doingmoderately well, although the volatile political situation in Angola is not conduciveto effective project implementation. As single sector projects, they are mainlyextensions of traditional project concepts which incorporate environmentalobjectives.

f) Supervision missions and environmental expertise

Substantially fewer resources are put into environmental project supervision thaninto project preparation and appraisal. In those instances where environmental ex-perts were included they came from within the Bank-either from the CDs orAFTES. AF2 has located an environmental specialist in the Nairobi office withconsiderable regional supervision responsibilities, while AF5 has a similar ar-rangement at the Resident Mission in Burkina Faso. Judging from mission com-positions listed in the Form 590, outside consultants are seldom employed for suchpurposes. AF4, meanwhile, has taken an interesting step by hiring local staff towork on environmental projects and programs in the resident mission in Nigeria.

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Some CD staff pointed out that, for many projects, cofinancers haveagreed to provide additional supervision expertise. From the supervision reports,this is not much in evidence. The February 1993 supervision missions on theKenya and the Sahelian projects are exceptions in that active donor participationwas evidently successful. In any case, the Bank should be careful about relying onenvironmental expertise from other agencies. For projects with major environ-mental focus, such as the 10 in this project sample, there are strong reasons forhaving Bank-associated environmental experts on supervision missions. The re-viewers felt that some key environmental issues in the 10 projects could have beenbetter examined had such experts been included. For example, the Mauritiugproject covers the infrastructure activities extensively, but is short on the criticalissues facing the two "driving engines" in the project-the new national park andthe economically important marine conservation program.

Several staff interviewed felt it was especially important to have environ-mental experts on supervision missions at the beginning of project implementationand thereafter at least once a year. Many commended the Sahelian Department andthe East Africa Department for having posted HQ staff with environmentalexpertise in field offices with multi-country supervision responsibilities. It wouldbe useful at this stage to assess the experience of field offices in project supervi-sion in terms of the balance and effectiveness of the Bank's own expertise in theField Offices, the use of local consultants, the expertise sent on supervision mis-sions (Bank and outside consultants), and the expertise provided by cofinancers. Inany event, the environmental expertise and the skill mix needed in supervisionmissions need to be assessed in more detail. This review reveals an urgent need forCDs to employ more environmental expertise on supervision missions. AFTESshould consider offering CDs consolidated supervision assistance for a carefullyselected group of environmental projects with broad cross-sectoral objectives, re-quiring the joint focus of senior-level expertise in environment, agriculture, andinfrastructure.

There is considerable uncertainty about standards for determining environ-mental ratings of projects under supervision. The supervision reports should ex-plain how environmental ratings are determined. At the same time, the Bankshould provide better guidance on which specific criteria are expected to be usedin arriving at useful "environmental" ratings. Specific environmental indicators ofperformance, including long-term sustainability issues, should be developed.

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g) Institutional and coordination issues in environmental project work

The Bank's traditional preference for simple management and organizational de-sign for project implementation is not reflected in these projects. Environmentalmanagement or natural resource management are concepts which generally involvemany different sectoral agencies and ministries. This is compounded by the factthat many of the institutions involved are new to the country as well as to Bankpolicies and procedures. Among the factors which make environmental projectsdifficult are: a) the need to set up new institutions; b) the need to incorporatecoordination in new or existing institutions; and c) the new technical emphasis-e.g., on environmental information, ecology, environmental management-createsa skill gap in the country which may require training to fill.

The three projects with national environmental planning focus-Mauritius,Madagascar, and Nigeria-have involved ministries of finance or planning, but itis not quite clear how much interest these agencies have shown in the implementa-tion stages. The bulk of project execution falls on new and not yet strong envi-ronmental institutions and on traditional sectoral ministries. One point comesthrough strongly in this review: new (public sector) environmental institutions(ONE in Madagascar, FEPA in Nigeria, and the Environment Department inMauritius) should be limited to a few manageable functions in their objectives andin their work programs. Otherwise, they may try to take on more than they canhandle effectively. Another important point is the rapid rise of dynamic privateinstitutions emerging as a positive force in implementation. Their role in projectimplementation is likely to have increasing strategic significance for environmentalactivities in Africa.

National environmental planning must coincide with economic and socialdecision-making. Without linkages, environmental planning loses credibility andeffectiveness. Both ONE and FEPA have shown signs of wanting to do more thanthey can manage, thus risking falling behind in overall national developmentplanning. The coordination body should refrain from being directly involved inoperational activities, however persuasively the donors may induce them to do so.Their functions should concern policy and program-not project coordination-andmonitoring and problem-solving rather than project execution tasks.

The three natural resource management projects cover many differentagencies responsible for rural activities, but they also add a strong element of de-centralization to local government levels and emphasize local participation. Theintersectoral links in these cases are expected to be driven by demands from localinstitutions in the field. Factors determining success of the projects include: howwell the institutions can respond to local levels; the capacity of local institutions;and the effectiveness of the Bank's project supervision.

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One institutional issue

Ownership is key to effective environmental missiefforts and long-term commitment. The ta enven tal (pact)country must feel an ownership of the pro- ae ments. Tinicds

ject or plan if it is to devote meaningful ef- cssedsin s fute As butfort and resources to it on a continuing ba- ceiste ate SR t u-sis. Sustainability of an environmental pro-ject is not possible if the country regards pervision reports. In all projectsthe project as a requirement imposed from th rating opnana envioutside or as a short-term lure for addi- romelangemntia pn-tional development funds. In the same way.ownership is a key factor determining be a major institutional objectivewhether or not the Bank and other donors and should be reported on inwill devote sustained and effective effort supervision reports.and resources.

h) Performance ratings

In the latest overall performance ratings, not a single project in this sample of 10environmental projects is rated "" or "4." Rather, nine are rated "2" and one israted "1a" (Benin NRM). The average for this sample is 1.9. Since the performanceratings of this sample are so unexpectedly encouraging relative to the average forthe rest of the Africa Region's portfolio, it is clear why AFR managers have so farhad no major concerns about environmental projects.

In the 1992 ARPP, environment was not listed as a separate category. Theratings of the 10 projects reviewed were covered under other categories. Acomparison of the latest ratings of these 10 projects with the average overall pro-ject ratings in the 1992 ARPP report for Africa Region reveals an interestingpoint. The average project rating of 1.9 for the above sample seems at first look toreflect a much higher optimism than the overall regional average of 2.15 in the1992 ARPP. In fact, compared to the averages listed for all sectors and thematiccategories mentioned in the Africa Region's ARPP report, the average for the 10environment projects would have placed it at the very top in terms of good im-plementation performancert2

To what extent is this encouraging picture related to the fact that most ofthese are young projects? Will the full effect of "complexity" factors be visibleonly later on? To answer these questions, let us next look at the "newness" factorand also some of the key complexity issues summarized in the Wapenhans Report.

Environment was not among the problem areas in last year's ARy. Infact, there were several indications of positive implementation experiences-in

2 Table 8, Page 33, Africa Region: FY92 Annual Report on Implementation and Supervision, Vol.1, December 11, 1992.

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sharp contrast to the alarm of the Wapenhans Report. The 1992 ARPP report3

concluded that these projects were "among the most innovative and responsive tothe change in strategy, and have resulted in improvement in project performancefor the forestry/environment sector."

Leaving aside the inappropriate term "forestry/environment sector," theBank's general experience is that major implementation problems are seldom fullyreflected in "3" or "4" ratings in Form 590 until several years into the supervisionphase. In the first few years after the project has been made effective, supervisionstaff tend to give the client the benefit of the doubt. The oldest of the 10 projects

was made effective less than three years ago. Furthermore, all 10 projects are of

recent origin. The Benin project was made effective last October, while the twoothers (Mali and Nigeria) were only made effective in early 1993. Clearly, theirratings are based on few field-tested results, and their implied optimism reflects toa large extent their newness in the portfolio.

It is safer to assume the general health of the Bank's environmental port-folio is closer to that reflected by the overall regional average rating of 2.15. Evenwith this modification, this is significant because of its difference from theWapenhans Report. Still, there is no room for complacency on this point-the

deeply rooted problems have yet to be faced in project implementation.

i) Sustainability issues

Just as the Bank has traditionally reviewed a single sector project in a larger sec-toral context, it should also bring out the larger sustainability issues affecting anenvironmental project. For example, the degree to which Madagascar's biodi-

versity program is able to slow the rapid rate of forest destruction-as well as the

elimination of habitats for the many important endemic species-should be moni-tored closely during project supervision. Supervision reports on Mauritius, other-

wise thorough, show a remarkable gap in reporting on major habitat destruction in

one of the two designated marine parks, with direct negative impact on the coun-

try's tourism potential. The same consideration applies to cofinancers. There is a

tendency among other donors to focus on "preservation"-i.e., protection of aspecies or area rather than long-term sustainable development.

The 590s establish "environmental ratings" for each supervision visit. An

examination of these ratings for the last two supervision missions of the 10 pro-jects in this sample show that they are generally very optimistic. Most are rated"1"; a few are rated "2"; and only one was one rated "3" (in the next to last su-

pervision on Madagascar). This review reveals considerable lack of clarity andsometimes lack of understanding of what these ratings mean. Each seems to reflect

an individual task manager's judgments which are difficult to compare with thosein other similar projects. The Bank should provide better guidance on which spe-cific criteria should be used in finding useful "environmental" ratings.

3 Agricultural Annex, "Forestry and Natural Resources, page A45, ibid.

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Environmental indicators of performance should include long-term sustainabilityissues.

The sustainability issues are closely interlinked with the institutional is-sues. The long-term sustainability dimensions can be fostered by institutionalizingnational and local capacity to undertake EA tasks. Another set of related issuesdeals with decentralization of project decision-making. Borrower establishment ofan institutional capacity for in-country EA policies and procedures may be one ofthe benchmarks for judgments on sustainability. Beyond this issue looms the largerquestion of finding useful operational benchmarks or indicators for sustainability.This is long overdue in the Bank and affects all regions, not just Africa. Urgentaction to develop operational benchmarks or indicators for sustainability isstrongly recommended and might best be undertaken by ENV.

IH. Global Environmental Facility (GEF)

GEF in project implementation

GEF project implementation, which only started in FY 93, is still in its pilot stage.So far, the main operational problems are in the preparation and appraisal stages.GEF projects are more complex and staff-intensive, and need local or internationalexpertise which is often hard to find. GEF projects also require longer timetablesthan regular Bank operations. Developing collaboration between the Bank andNGOs has been difficult, and a substantial effort will be required to achieve mu-tual trust and understanding. The complexity of GEF projects is also proving diffi-cult for governments, especially where community consultation and participation isinvolved. Obtaining government funding has been exceptionally difficult in somecountries because GEF is often viewed as representing global interests more thancountry priorities.

Only four GEF investment projects (Mauritius Bagasse Energy, GhanaCoastal, Congo Wildlands Management, and Seychelles Biodiversity) have begunimplementation. Two more may start soon (Kenya Tana River and UgandaBiological Diversity). Guidance is needed, and it has been recommended that theScientific and Technical Advisory Panel (STAP) concentrate on strategic issuesrather than continuing the project by project approach which it has so far followed.

Once GEF is operating on a permanent basis, it will have to move from anad hoc approach to a strategic approach, both at the regional and country levels.The Bank should develop an Aftica-wide strategy with a solid scientific basis,taking capacity constraints into account. This requires that the leadership be withinthe Africa Region. At the country level national strategies are needed, andNational Environmental Action Plans (NEAPs), where they exist, can provide thefoundations for these strategies.

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So far, GEF projects involve many agencies and institutions which are un-familiar with Bank operational policies and procedures, especially procurement. Inaddition, the remoteness of many GEF project sites has caused communicationproblems, and in-country staff recruitment has been unusually slow because of thescarcity of suitable environmental experts (whether local or international) for fieldassignments. Until recently, these areas of study offered limited career prospects,and, therefore, few Africans trained in these fields. Suitable international expertshave also been hard to find. Career possibilities in some areas, such as tropicalbotany, appear to be dwindling in developed countries, and interest in study hasfallen compared to several few decades ago. Existing expertise must be identified,and training should be encouraged to develop local expertise.

For these and other reasons, GEF projects may require a much longer timespan than is normal in other Bank operations. They are therefore a departure fromthe normal procedures for Bank staff. Additionally, the GEF is viewed as "out ofthe mainstream" of Bank operations, or an "add on." This perception can only bechanged by bringing the GEF process into the mainstream of Bank activities.

GEF projects involve intensive collaboration with NGOs-a collaborationwhich has produced mixed results. Although NGOs have often played a catalyticrole at the start, mutual mistrust between the Bank and NGOs continues to obstructcomfortable and cooperative relationships. Fueling this mistrust is the apparentinconsistency in Bank policy on release of project documents. The World Bank-NGO consultations for the Africa region, which were organized by AFTEN andheld in 1991 and 1992, were effective in building understanding and cooperationbetween the NGO community and the Bank for the GEF. These consultationsshould be reinstated.

As in the other environmental projects reviewed, the GEF needs specificenvironmental expertise on supervision missions. In addition, wherever possiblein-country experts, both in government and in the NGO community, shouldmonitor GEF activities.

The approved GEF projects in the Africa Region are:

FIRST TRANCHE investment projects:CONGO WILDLANDS MANAGEMENT AND PROTECTION: The grant wasonly recently made effective. Implementation is in the start-up phase.KENYA TANA RIVER PRIMATES: The completion of preparation awaitsagreement on required resettlement. This now seems solved and would notrequire any involuntary resettlement. Appraisal is planned for this fall.MAURITIUS BAGASSE ENERGY: Appraised in September 91, it was ap-

proved in February 92 and is now under implementation.UGANDA BIOLOGICAL DIVERSITY: GEF approved in June 93 with ap-praisal scheduled for this fall.

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SECOND TRANCHE investment projects:GHANA COASTAL WETLANDS: Approved by the Board last October, it isnow beginning implementation.LAKE MALAWI: Appraised last February, approval is expected thisSeptember.SEYCHELLES BIODIVERSITY: Approved by the Board last November, it isnow being implemented.

THIRD TRANCHE investment projects:CAR LANDSAT: After newly completed preparation, appraisal is plannedfor this August but status is still uncertain.ZIMBABWE NATIONAL PARKS: Under preparation.

FOURTH TRANCHE investment projects:COTE D'IVOIRE CROP WASTE: Under preparation.MALI HOUSEHOLD ENERGY: Preparation completed and now under ap-praisal.MOZAMBIQUE TRANSFRONTIER: Preparation delayed because of securityproblems.NIGERIA GAS FLARE REDUCTION: Delays in completing preparation.WEST AFRICA GAME RANCHING: Under preparation.

FIFTH TRANCHE investment projects:CAMEROON BIODIVERSITY: Preparation funding just approved.

IV. Environmental Assessments

Environmental Assessments (EAs) are recent Bank project requirements. Theywere introduced in 1989 for projects initiated after October 15, 1989, and, so far,experience with EAs has been satisfactory. The EA unit in AFTES and the CDshave agreed on the classification of EAs, and the EA results are well reflected inthe SARs. There is wide agreement that the EA process has been beneficial toproject development in the Africa Region and in the countries involved. Localconsultations are an important part of this experience, and, While complicated andnew to most governments, as well as the Bank, they have progressed well.

In 1991 a revised OD on EAs added importance to "Category B" projectsand put emphasis on Mitigation Plans. EA preparation takes place early in projectpreparation and has a critical influence on project design. The Africa Region's EAexpertise (in AFTES) has been largely involved in pre-Board stages of "CategoryA" projects. So far, the CDs have asked AFTES for very little assistance onproject supervision.

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CATEGORY A PROJECTS:

Since EAs are new, there is little supervision experience with them. Excludingprojects approved since July last year, the following eight "Category A" projectsare under supervision in the Africa Region. However, it should be noted that mostof these are older projects which the CDs agreed to be so classified "ex post"-i.e., they were initiated before the benchmark date set in the OD. They areunevenly distributed among the six CDs; and three-fourths of them are projectsfrom AF2 and AF6:

FY 90: SOMALIA: FARAHAANE

FY 91: UGANDA: POWER IIIUGANDA: LIVESTOCK

NIGERIA: OSo CONDENSATE

BOTSWANA: TULI BLOCK ROADS

FY 92: MAURITIUS SUGAR ENERGY

LESOTHO: HIGHLANDS WATER PROJECT

MALAWI: POWER VI.

The Annual Review of Environmental Assessments 1992 gives specialattention to two EA samples from the Africa Region: Malawi Power V andMauritius Bagasse Energy Development (GEF), which is linked to the larger SugarEnergy Project (above). The Board report is complimentary to both projects, in-dicating good staff work in the CDs and strong technical support provided byAFT. The Board report reveals five significant lessons from these two projects:

(1) The EA experience prompted the Malawi Government to use similar EA pro-cedures for other projects.(2) With AFTEN help, the EA report could be produced in absence of any countryEA process (Malawi).(3) Public consultation was carried out without delaying the project or significantlyincreasing its cost (Malawi).(4) Even a project with environmental objectives can have negative effects(Mauritius).(5) Project alternatives existed which could be referred to for comparison. It wouldbe useful if similar project alternatives could be used more generally in such pro-jects (Mauritius).

The EA unit in AFTES reports that it has not encountered any seriousproblems with the CDs about EA project classifications. Normally, there is ascreening process where the TM proposes the classification for the project andAFTES concurs. Since EA work started in 1989, the Africa Region has had no un-resolved issues between EA experts in AFTES and CD task managers about hav-ing EA results fully reflected in SARs. The CDs have taken this work seriously,and several EAs have led to redesigned projects or to substantial changes in pro-ject components.

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Local consultations for EAs have progressed well in spite of some signifi-cant difficulties. Most governments have no similar requirements nor relevant ex-perience at the national level. While their degree of genuine commitment mayhave varied, most governments have made commendable efforts to abide by theBank's local consultation requirements. However, many donors have been slow infollowing the Bank's example in this regard.

In Africa, local consultations have been mostly oral. Radio has been usedin several projects to notify local people about upcoming local hearings. However,given Africa's multitude of different local languages and its high illiteracy in mostrural areas, the expected "paper trail" is difficult to ensure. The EA should listmeetings with locations and a general description of the audience, plus the results.

So far there has been little CAM demand for EA expertise from AFTESfor supervision, although, last fiscal year saw CAM requests rising for EA exper-tise for supervision missions. CDs have often used consultants for supervision pur-poses with good results, and have generally consulted AFTES on their selection.

For the project supervision stage, AFTES does not monitor how EA re-sults, reflected in SARs, are being implemented. CD experiences are conveyed onan ad hoc basis to AFTES EA experts, but no system now exists in AFTES, orelsewhere in the Region, for following overall EA implementation experiences.There is a gap between the sign-off, on EA at the completion of appraisal and thedesign of the supervision plan. The EA unit in AFTES should be consulted for allA and B category projects about which actions should be included in the supervi-sion plan for each project, and AFTES should receive copies of each supervisionreport. It should also have an opportunity to comment on the scope of TORs be-fore departure of supervision missions. AFTES should also assume a more directinvolvement in monitoring the implementation of EA results and should derivespecific operational lessons for future project development.

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CATEGORY B PROJECTS

Compared to the two following years, many projects were classified as category B

projects at the start of EA procedures in 1989.

FY90 FY91 FY92

CD1 8 3 1CD2 8 4 5CD3 7 6 3CD4 8 4 7CD5 1 2 3CD6 3 4 4TOTAL 35 23 23

MITIGATION PLANS

Mitigation plans (MPs) are one part of the process which needs improvement. The

plans must be substantially more specific, and there must be more follow-up, al-

though unnecessary bureaucratic requirements should be avoided. Category B

projects gained new importance with the revised OD on EAs in 1991 when MPs

were emphasized more, although the OD is vague on the specific requirements.

MPs require neither separate EA documentation nor similar local consultation.

However, they are expected to be recognized specifically in project preparation

and reflected in the final appraisal.

Experience with mitigation plans so far indicates that CDs have generally

taken MP work seriously. There is no single reported case of CD staff rejecting

the ruling of the EA unit in AFTES. Sometimes, as a result of planning for an MP,

CD staff have decided that some project components should be dropped since

mitigation efforts would be too cumbersome. Three remaining problems are: (a)

MPs are sometimes not completed until near the date of Board presentation; (b)SARs do not document well what specific actions are expected during implemen-

tation (although lately this has improved); and, (c) supervision reports seldom

cover the follow-up to the actions agreed upon under MPs. Clearly, all projectswith a MP should include a discussion of the progress achieved in each supervi-

sion report.

V. Conclusions

The overall ratings for the 10 projects reviewed indicate that there is less reason

for concern about the implementation performance of Bank-funded environmentalactivities than expressed in the Wapenhans Report. At least, project ratings have

so far been relatively favorable for those in the Africa Region. However, as this

review has revealed, there are good reasons to be cautious because the real test of

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implementation has not yet been faced in most of the major environment activitiesinitiated in Africa since the reorganization of 1987. The environmental expertisebrought on board in the Africa Region, as well as the skills developed since then,has been almost applied exclusively to the design, planning, preparation and ap-praisal of new activities-very little has been applied to implementation.

This review has addressed two broad areas of concern: one relating to thedegree of in-country "ownership" and commitment, and also its capacity to carryout these new activities; the other relating to the Bank's ability to handle these newactivities, including providing the donor leadership throughout the project imple-mentation phase. A missing element which should be created is a monitoring sys-tem for identifying implementation issues of wider interest-i.e., beyond a singleproject, drawing lessons from similar experiences, and making these available tonew projects through operational guidance .

African countries have made considerable progress in identifying and tak-ing on new environmental initiatives-although part of this interest is clearly linkedto the expectation of new and larger amounts of aid. This preoccupation places apremium on planning new projects but less attention to implementation. TheNigeria project took almost a year to become effective. Once approved by theBoard, the Madagascar project saw diminished political interest in supporting thenew institution responsible for coordination at the national level. The Mauritiusproject experienced a substantial delay in establishing the new national park andthe marine protection program. Beyond this issue, the new environmental activitiesbring into play new institutions unfamiliar with donor assistance and, in particular,Bank policies and procedures. They also call for broader than usual localcommunity involvement, coordination between many different public sector insti-tutions, and, in many cases, larger than usual private sector involvement. Finally,they may call for an expertise which is in very short supply locally and which of-fers few career prospects to encourage study.

The Bank has had considerable success in getting new environmental tasksrolling. Several of these, such as EA and GEF, are pioneering actions. However,so far implementation assistance has seemed to suffer, and supervision missionsare using too little environmental expertise. Retraining sector specialists andeconomists is a fine objective but is no substitute for involving high caliber envi-ronmental expertise on the supervision team. Placing experts in field offices is agood idea and should be considered beyond the present arrangements in Burkinaand in Nairobi. Bringing in experts from other donors is also useful but, again, nosubstitute for Bank in-house capacity. The Bank is increasingly assuming a leader-ship role for joint donor action in national environmental programs, and thisshould be expanded to include their close participation in ensuring that the coun-try's "ownership" is fostered in these activities. Moreover, the multidonor pro-grams must be clearly cooperative ventures, and should be monitored to ensurethat donor competition and contradictory positions do not sabotage the process.The admonition about donor coordination by African leaders at the most recent

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GCA meeting should be taken seriously for project preparation and implementa-tion.

Country and donor implementation problems can be significantly reducedby early consultations among all the stakeholders in an environmental activity. Theextensive consultation process in the recent health project in Chad, involving localand national institutions as well as donors (using the ZOPP methodology), is avaluable experience. The basic elements of this approach deal with many of theproblems noted in this review and should be studied to see how they apply to theprojects covered here.

There must be a focal point to monitor the implementation of projects withmajor environmental focus as well as the progress on EAs and on Mitigation Plansfor "Category B" projects, and the GEF activities just getting started. Such acapacity, perhaps in the form of an Implementation Unit, should be located inAFTES and should have overview capacity for all the task categories covered inthis review.

Each year, there should be a review carried out by reviewers who aTe bothindependent and well acquainted with the Bank and its African operations. Itshould focus on a complete sample of "environmental" projects as well as EAs andthe GEF. The review should give particular attention to the progress made on theproblems and recommendations identified in the previous reviews. The reviewcould use a methodology similar to that used in this one, but it would be more use-ful if future reviews had more information about what has actually happened onthe ground than is possible from the existing written record. To obtain this impor-tant dimension would require additional emphasis on consultations with Bank staffand others acquainted with the projects in the field. The possibility of field visits toselected projects should also be considered.

VI. Recommendations

*Special efforts should be made to establish effective donor coordination mecha-nisms throughout the project cycle-before problems arise.

*Donors should be willing to fund projects which are within the framework of anational environmental program. They should also agree to joint modalities forimplementation assistance. Borrowers, on the other hand, should demonstrate thatenvironment policies and projects are pursued as part of a genuine national and lo-cal commitment and not because it attracts new development assistance.

eWhenever reforms related to land tenure conditions are required (e.g., theBurkina Faso project) for reaching estimated project benefits, such action shouldbe taken by the government before Board presentation, rather than left as a condi-

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tion of effectiveness or as part of time-bound requirements during the supervisionphase.

*Representatives of the key national and, if relevant, local agencies responsible forimplementing projects should participate at an appropriate stage in the loan/creditnegotiations.

*Field office experiences with project supervision should be assessed to determinewhat is the proper, i.e., effective balance between the Bank's expertise in field of-fices and the use of local consultants, compared to expertise sent on supervisionmissions (Bank and outside consultants) as well as expertise provided by cofi-nancers.

*For projects with major environmental focus, such as the 10 in this project sam-ple, there are strong reasons for having Bank-associated environmental experts onsupervision. The Bank should be careful about excessive reliance on environ-mental expertise from other agencies.

*The skill mix needed in supervision missions should be studied more. This reviewreveals an urgent need for Country Departments to employ more environmentalexpertise on supervision missions.

*The Bank should provide better guidance on which criteria determine useful"environmental" ratings. Specific environmental indicators of performance shouldbe developed. Long-term sustainability issues must be included.

*Supervision reports should explain how environmental ratings are arrived at.

*AFTES should offer CDs consolidated supervision assistance for a carefully se-lected group of environmental projects with broad cross-sectoral objectives, re-quiring the collaboration of senior-level expertise in environment, agriculture, andinfrastructure.

*National environmental planning should dovetail with economic and social deci-sion-making.

*Special care should be given to limiting new (public sector) environmental insti-tutions (ONE in Madagascar, FEPA in Nigeria, and the Environment Dept. inMauritius) to a few manageable functions. Otherwise, they might take on morefunctions than they can handle. Attention should be given to the rapid rise of dy-namic private institutions emerging as a positive force in implementation. The roleof such bodies in project implementation is likely to have increasing strategic sig-nificance for environmental activities in Africa.

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*In all environmental projects with national scope and certainly those relating tonational environmental management and planning, EA capacity building should be

a major institutional objective and should be included in supervision reports.

*Just as the Bank has traditionally reviewed a single sector project in a larger sec-toral context, it should also bring out the larger sustainability issues affecting anenvironmental project.

*There is an urgent need to develop and obtain Bank-wide agreement on opera-

tional benchmarks or indicators against which to measure progress on sustainabil-ity objectives.

eThe greatest need in the EA process is for improved follow-up. For the project

supervision stage there is a need for monitoring EA results, including the

Mitigation Plans. It would be appropriate for the EA unit in AFTES to assume

more direct involvement in monitoring and implementation of EA results and toderive specific operational lessons for future project development.

*Mitigation Plans need to be strengthened. They should be substantially more

specific and assure that there is more follow up, although it is important to avoidunduly bureaucratic requirements.

*All projects with a Mitigation Plan should include discussion of progress achievedin each supervision report.

*There is an inadequate link between sign-off on EA at the completion of appraisaland the design of the supervision plan. The EA unit in AFTES should be consulted

for all A and B category projects on the specific action which should be includedin the supervision plan for each project.

*There is a particular need to include environmental expertise on the supervision

missions for GEF projects. In addition, wherever possible there should be closemonitoring of the GEF activities by in-country experts, both in government and inthe NGO community.

*The GEF process should be brought into the mainstream so Bank staff and su-pervisors regard it as such.

*The Bank should develop an Africa-wide GEF strategy under the leadership ofthe Africa Region. National GEF strategies should also be developed. NationalEnvironmental Action Plans (NEAPs) provide the foundation for such strategieswhere they exist. Maximum use should be made of whatever relevant environ-mental work has been done.

*AFTES should become more proactive on implementation issues. It should estab-lish a better operational focus for monitoring, for drawing lessons from implemen-

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tation experiences, and for assisting implementation of all environmental activitiesin the Africa Region, including EA tasks and GEF. Specifically, it should appointa senior staff to serve as full-time Implementation Adviser.

*There should be an annual, independent review similar to this one, which againfocuses on as complete a sample as possible of "environmental" projects, EAs, andGEF. Particular attention should also be given to progress made on the problemsand recommendations identified in the previous reviews, and there should beefforts to determine what is happening in the field. The reviewers should be inde-pendent but well acquainted with the Bank and its African operations.

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ANNEX

Resettlement

Resettlement in Bank projects is covered elsewhere in the ARPP report. However,because of its importance in relation to environmental issues, it is briefly men-tioned here.

The active Africa portfolio includes 25 projects in which resettlement affects about100,000 people. The infrastructure sector dominates with urban projects account-ing for the majority, followed by water supply and transportation. The resettle-ment portfolio is concentrated in a relatively few countries which share character-istics of high population density and governments which tend to invest in large-scale projects.

Generally, resettlement components have not hindered project implemen-tation. Compared to other regions, the number of resettled people in Africa issmall, and, for economic reasons, governments try to keep relocation to a mini-mum. Some projects have started out with resettlement components which havenot been implemented because of a failure to meet policy conditionality, whileother projects have successfully completed resettlement processes. The principalstrategies in preparing and implementing resettlement programs are sustained at-tention to review resettlement plans, use of specialists in preparation and supervi-sion, continuous sharing of experience among task managers and the TechnicalDepartment, and capacity building within local governments and NGOs.

Experience indicates that in the future more attention must be given to re-settlement issues from the beginning and throughout the project cycle. This meansmore sociological expertise in the Africa Region-ideally including one sociologistin each CD to deal with resettlement and other social issues-as well as continuedcollaboration between task managers, the Regional Technical Department, andENVSP.

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