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JICA Study for Review of

“JICA Guidelines for


Environmental and Social
Considerations”

Final Report

February 2020

Japan International Cooperation Agency


(JICA)
This report contains a summary and citations of other organizations' official documents including
environmental and social safeguard policies. Details of the referred documents need to be confirmed with
the originals. Translations as well as views and opinions expressed in the adaptations of the original works
are the sole responsibility of the author of this report.
Final Report
JICA Study for Review of JICA Guidelines for Environmental and Social Considerations February 2020

JICA Study for Review of


JICA Guidelines for Environmental and Social Considerations
Final Report

Table of Contents

CHAPTER 1 INTRODUCTION ........................................................................................................... 1-1


1.1 Background of the Study.......................................................................................................... 1-1
1.2 Objective of the Study.............................................................................................................. 1-1
1.3 Scope of the Study ................................................................................................................... 1-1
1.4 Study Methodology .................................................................................................................. 1-7
CHAPTER 2 RESULTS OF THE REVIEW STUDY ........................................................................... 2-1
2.1 Summary of Reviewed Projects ............................................................................................... 2-1
2.1.1 Projects by Region................................................................................................................. 2-1
2.1.2 Projects by JICA Project Scheme .......................................................................................... 2-2
2.1.3 Projects by Sector .................................................................................................................. 2-2
2.2 Application results of JICA GL for Environmental and Social Considerations for 100 Reviewed
Projects ..................................................................................................................................... 2-2
2.2.1 Review Results of "I. Basic Matters" .................................................................................... 2-3
2.2.2 Review Results of "II. Process of Environmental and Social Considerations" ..................... 2-4
2.2.3 Review of "III. Procedures of Environmental and Social Considerations" ......................... 2-10
2.2.4 Appendix 1 – 6 Environmental and Social Considerations Required for the Project Proponents
2-16
2.2.5 Case Analysis of Ayago Hydroelectric Power Plant Development Project ........................ 2-51
CHAPTER 3 CHANGES AND TRENDS OF EXTERNAL ENVIRONMENT .................................. 3-1
3.1 Government Policies and International Aid ............................................................................. 3-1
3.1.1 Development Cooperation Charter ........................................................................................ 3-1
3.1.2 Promoting Quality Infrastructure Investment ........................................................................ 3-4
3.1.3 G7 Ise-Shima Principles for Promoting Quality Infrastructure Investment .......................... 3-6
3.1.4 Trends of International Aid ................................................................................................... 3-6
3.2 Changes after the Enforcement of Current JICA GL ............................................................... 3-9
3.2.1 Responsibility of JICA .......................................................................................................... 3-9
3.2.2 JICA’s New Assistance Program Started after the JICA GL Enforcement in 2010 ............ 3-12
3.3 Summary of MDBs’ SGPs ..................................................................................................... 3-20
3.3.1 Current Status and Trend of MDBs’ SGPs .......................................................................... 3-20
3.3.2 Comparison of WB’s Previous SGPs with the New ESF .................................................... 3-24
3.3.3 Policies of MDBs on Specific Safeguards Topics ............................................................... 3-41
3.4 Changes in Surroundings related to the Review of JICA GL for Environmental and Social
Considerations and its Process ............................................................................................... 3-43
3.4.1 Ruggie Principles (Guiding Principles on Business and Human Rights: Implementing the
United Nations “Protect, Respect and Remedy” Framework) ............................................. 3-43
3.4.2 SGPs of WB, ADB and IFC as the standards and Good Practices to be referred................ 3-44
3.4.3 Quantification of Environmental and Social Costs and Benefits in Japan and MDBs’ Projects
3-45
3.4.4 Alternative Considerations Especially for “Without Project Scenario” .............................. 3-46
3.4.5 Natural Disaster aspect in the EIA for Projects in Japan and Funded in MDBs ................. 3-48
3.4.6 Climate Change issue in the ESIA under MDBs’ SGP ....................................................... 3-52
3.4.7 Indivisible Projects, Derivative and Secondary Impact and Cumulative Impact under MDBs’
SGP...................................................................................................................................... 3-54
3.4.8 Consideration for Protected Area, Biodiversity and Critical Natural Habitats in the ESIA

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under MDBs’ SGP............................................................................................................... 3-55


3.5 Comparison among Bilateral Donors’ SGPs.......................................................................... 3-63
3.6 Japan's Treaty Ratification ..................................................................................................... 3-74
3.7 Achievements and Challenges of JICA 's Capacity Development Programs......................... 3-78
CHAPTER 4 DRAFT DISCUSSION POINTS FOR REVISION OF JICA GL ................................... 4-1

ANNEX: RECEIVED PUBLIC COMMENTS

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JICA Study for Review of JICA Guidelines for Environmental and Social Considerations February 2020

List of Tables
Table 1-1 List of Reviewed Projects ................................................................................................. 1-2
Table 1-2 Field Surveys Conducted for 8 Projects ............................................................................ 1-7
Table 1-3 Review Survey Item Sheet ................................................................................................ 1-8
Table 2-1 Review Results of Survey Item Sheet for “Chapter I. Basic Matters” .............................. 2-3
Table 2-2 Projects which Emergency Measures were Applied ......................................................... 2-4
Table 2-3 Example of Qualitative Without-Project Scenario .......................................................... 2-13
Table 2-4 Example of Quantitative Without-Project Scenario ........................................................ 2-13
Table 2-5 Examples of Alternatives ................................................................................................ 2-13
Table 2-6 Overview of the Projects which have an Indivisible Project ........................................... 2-24
Table 2-7 Projects with Derivative or Secondary Impacts and Mitigation Measures Implemented 2-24
Table 2-8 Projects with Cumulative Impacts and Mitigation Measures Implemented .................... 2-25
Table 2-9 Details of the Project Located in the Vicinity of the Area Designated as "Protected Areas
that are Specifically Designated by Laws or Ordinances for the Conservation of Nature or
Cultural Heritage" ............................................................................................................ 2-26
Table 2-10 Grounds and Verification Results that are Considered to be Critical Natural Habitats 2-28
Table 2-11 Comments from the Public Consultation Meetings which were Reflected ................... 2-30
Table 2-12 Projects which Lower the Resistance of the Project Site and Increases the Disaster Risk 2-
33
Table 2-13 Outline of Good Practice for Consultations .................................................................. 2-33
Table 2-14 Example of Consultation Challenges ............................................................................ 2-35
Table 2-15 Examples of Conducted Stakeholder Analysis ............................................................. 2-37
Table 2-16 Good Practices in Environmental and Social Considerations ....................................... 2-38
Table 2-17 Issues Pointed out to the Project Proponent and/or JICA by the Third Party................ 2-39
Table 2-18 Project for which an Objection has been Filed to JICA ................................................ 2-40
Table 2-19 Cases of Consideration for the Socially Vulnerable Groups ......................................... 2-41
Table 2-20 Responses to Advice on Gender and Children's Rights ................................................ 2-44
Table 2-21 Changes in the Number of PAPs in the Environmental Review and Monitoring Stages and
Reasons ............................................................................................................................ 2-45
Table 2-22 Project Categorization in Power Transmission and Distribution Line Sector and
Agriculture Sector ............................................................................................................ 2-49
Table 2-23 Discussion and Situation at the Advisory Committee ................................................... 2-51
Table 2-24 Responses to Advisory Committee’s Advices at the Implementatio20ge ..................... 2-53
Table 3-1 Outline of Development Cooperation Charter .................................................................. 3-1
Table 3-2 Outline of PSIF and Support for SMEs and SDG Businesses......................................... 3-12
Table 3-3 PSIF Projects upto December 2018 ................................................................................ 3-13
Table 3-4 Support for SME/SDGs Business (1) Promotion Survey (SME Support) ...................... 3-15
Table 3-5 Support for SME/SDGs Business (2) Feasibility Survey (SME Support) ...................... 3-16
Table 3-6 Support for SME/SDGs Business (3) Verification Survey (SME Support) .................... 3-17
Table 3-7 Previous Support Projects which are Classified as Support for SDGs ............................ 3-18
Table 3-8 Summary of MDBs’ SGPs .............................................................................................. 3-20
Table 3-9 Status of MDBs’ SGPs and Their Revision .................................................................... 3-22
Table 3-10 Major Differences between Previous SGPs and the ESF/ESS ...................................... 3-24
Table 3-11 Category of Environmental Component Shown in the “Basic Matter”......................... 3-49
Table 3-12 Projects that have Selected Parameters related to Natural Disaster in their EIA under the
Japanese EIA Act ............................................................................................................. 3-50
Table 3-13 Requirements on GHG Emission .................................................................................. 3-52
Table 3-14 Analysis of Alternative Considerations on GHG Emission Reduction which is Technically
and Financially Feasible and Cost Effective .................................................................... 3-54
Table 3-15 Definition of Associated Facility under MDBs’ SGP ................................................... 3-54
Table 3-16 Definition of Indirect Impact/Secondary Impact under MDBs’ SGP ........................... 3-55
Table 3-17 Definition of Cumulative Impact under MDBs’ SGP ................................................... 3-55
Table 3-18 Definition of Habitats.................................................................................................... 3-58
Table 3-19 Requirements for the Development Project in the Natural Habitat ............................... 3-59

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JICA Study for Review of JICA Guidelines for Environmental and Social Considerations February 2020

Table 3-20 Requirements for the Development Project in the Critical Natural Habitat/Critical
Habitat ............................................................................................................................. 3-59
Table 3-21 Requirements for the Protected Areas ........................................................................... 3-61
Table 3-22 (1) Survey on Bilateral Donor Agencies' SGPs (France, Germany, UK)...................... 3-64
Table 3-23 Status of Ratification of International Treaties Related to Environmental and Social
Considerations ................................................................................................................. 3-74
Table 3-24 Results of Environmental and Social Considerations Training ..................................... 3-79
Table 4-1 Draft Discussion Points for Revision of JICA GL ............................................................ 4-2

List of Figures
Figure 2-1 Reviewed Projects by Region .......................................................................................... 2-1
Figure 2-2 Number of Reviewed Projects by Sector ......................................................................... 2-2
Figure 2-3 Percentage of SHM Participants in EIA for Category A Projects.................................. 2-36
Figure 2-4 Percentage of SHM Participants in RAP for Category A Projects ................................ 2-36
Figure 3-1 Promotion of Quality Infrastructure................................................................................. 3-6

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List of Abbreviation
ADB Asian Development Bank
AFD Agence Française de Developpement
AfDB African Development Bank
AIP Access to Information Policy
ARAP Abbreviated Resettlement Action Plan
ASEAN Association of Southeast Asian Nations
AusAID Australian Agency for International Development
BMP Biodiversity Management Plan
BMZ German Federal Ministry for Economic Cooperation and Development
BOD Biochemical Oxygen Demand
BOP Base of the Economic Pyramid
BP Bank Procedures
C/P Counterparts
CDC Commonwealth Development Corporation, UK
CEXIM Export-Import Bank of China
CO2 Carbon Dioxide
COP21 UNFCCC 21st Conference of Parties
CR Critically Endangered
D/D Detailed Design
DAC Development Assistance Committee
DFID Department for International Development, UK
DF/R Draft Final Report
EA Environmental Assessment
EBRD European Bank for Reconstruction and Development
ECC Environmental Clearance Certificate
EDCF/KEXIM Economic Development Cooperation Fund/Export-Import Bank of Korea
EDF European Development Fund
EHS Environment, Health and Safety
EIA Environmental Impact Assessment
EIRR Economic Internal Rate of Return
EMoP Environmental Monitoring Plan
EMP Environmental Management Plan
EMU Environmental Monitoring Unit
EN Endangered
EP The Equator Principles
ERP Emergency Response Plan
E/S Engineering Service
ESCP Environmental and Social Commitment Plan
ESDD Environmental and Social Due Diligence
ESF Environmental and Social Framework
ESIA Environmental and Social Impact Assessment
ESMF Environmental and Social Management Framework
ESMP Environmental and Social Management Plan
ESMS Environmental and Social Management System
ESS Environmental and Social Standard
EU European Union
F/R Final Report
F/S Feasibility Study
FAO Food and Agriculture Organization
FAQ Frequently Asked Questions
FGD Focus Group Discussion
FI Financial Intermediary
FPIC Free, Prior and Informed Consent / Free, Prior and Informed Consultation
GCF Green Climate Fund
GCG Green Credit Guidelines
GHG Green House Gas
GIIP Good International Industry Practice
GN Guidance Note
GRM Grievance Redress Mechanism
GTZ Gesellschaft für Technische Zusammenarbeit
HIV/AIDS Human Immunodeficiency Virus/Acquired Immuno-Deficiency Syndrome
IBA Important Bird Areas
IBRD International Bank for Reconstruction and Development
IDA International Development Association
IDB Islamic Development Bank
IDB Inter-American Development Bank
IEE Initial Environmental Examination
IFC International Finance Corporation

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IFC PS IFC Performance Standards on Environmental and Social Sustainability


ILO International Labor Organization
IMO International Maritime Organization
IP/SSAHUTLC Indigenous Peoples/ Sub-Saharan African Historically Underserved Traditional Local Communities
IPCC Intergovernmental Panel on Climate Change
IPP Indigenous Peoples Plan
IRP Income Restoration Program
ISO International Organization for Standardization
IUCN International Union for Conservation of Nature
JCM Joint Crediting Mechanism
JICA Japan International Cooperation Agency
JICA GL JICA Guidelines for the Environmental and Social Considerations
JIS Japan Industrial Standard
JSP Joint Strategic Plan
KBA Key Biodiversity Area
KFW Kreditanstalt fur Wiederaufbau, Germany
LARAP Land Acquisition and Resettlement Action Plan
LMP Labour Management Procedure
MCC Millennium Challenge Corporation, USA
MDBs Multilateral Development Banks
MDGs Millennium Development Goals
MIGA Multilateral Investment Guarantee Agency
MOE Ministry of Environment of Japan
MOFA Ministry of Foreign Affairs of Japan
MOU Memorandum of Understanding
M/P Master Plan
NDC Nationally Determined Contributions
NEDA Neighbouring Countries Economic Development Cooperation Agency, Thailand
NEXI Nippon Export and Investment Insurance
NGO Non-Governmental Organizations
NO 2 Nitrogen Dioxide
NOx Nitrogen Oxides
NT Near Threatened
O&M Operation & Maintenance
ODA Official Development Assistance
OECD Organisation for Economic Co-operation and Development
OHSM Occupational Health and Safety Measure
OPIC Overseas Private Investment Corporation, USA
OP Operation Policy
PAH Project Affected Household
PAP Project Affected Person
PM2.5 Particulate Matter 2.5
PMU Project Management Unit
PPP Public Private Partnership
PSIF Private Sector Investment Finance
RAP Resettlement Action Plan
ROW Right of Way
RPF Resettlement Policy Framework
SDGs Sustainable Development Goals
SEA Strategic Environment Assessment
SEP Stakeholder Engagement Plan
SGP Safeguard Policy
SHM Stakeholder Meeting
SIA Social Impact Assessment
SME Small and Medium-Sized Enterprise
SOx Sulphur Oxides
SPS ADB Safeguard Policy Statement
TOR Terms of Reference
TSS Total Suspended Solids
UN United Nations
UNESCO United Nations Educational, Scientific and Cultural Organization
UNFCCC United Nations Framework Convention on Climate Change
US EPA United States Environmental Protection Agency
USAID United States Agency for International Development
VPP Vulnerable People’s Plan
VU Vulnerable
WB The World Bank
WG Working Group
WHO World Health Organization

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JICA Study for Review of JICA Guidelines for Environmental and Social Considerations February 2020

CHAPTER 1 INTRODUCTION

1.1 Background of the Study

Section 2.10.2 of the JICA Guidelines for the Environmental and Social Considerations (hereafter
referred to as “JICA GL”), which were adopted in April 2010, specifies that “JICA will create a
comprehensive review of the guidelines within ten years of their enforcement on the bases of its
findings. Revisions will be made as needed, based upon the results mentioned above.” After the
implementation of JICA GL in 2010, JICA GL have been applied to approximately 1,800 projects
as of the end of JICA’s fiscal year (FY) 2016.

Over the years, the conditions surrounding the planning and implementation of JICA projects and
JICA GL have been changed due to the new development, such as : (1) the international cooperation
strategy of Japanese government, such as the Cabinet’s decision on the Development Cooperation
Charter in February 2015, and government policy to promote quality infrastructure investment; (2)
international development goals, namely the adoption of the Sustainable Development Goals
(SDGs) at the UN Summit in September 2015; and (3) relevant safeguard policies (SGPs) including
WB’s new Environmental and Social Framework (ESF) which was approved by the WB’s Board of
Executive Directors in August 2016 and enforced from 1st October 2018.

1.2 Objective of the Study

The objective of the study is to employ the following steps to identify the draft discussion points
in order to comprehensively consider the revision of JICA GL in the next stage planned after
FY2019:

 To review environmental and social safeguard practices under JICA GL in the past projects;

 To study changes in the conditions surrounding JICA projects;

 To identify and analyze draft discussion points for comprehensive review of JICA GL planned
after FY2019, in consultation with the Advisory Committee of Environmental and Social
Considerations and other external stakeholders.

1.3 Scope of the Study

The reviewed projects were shortlisted from approximately 1,800 projects for which the agreements
were signed by the end of JICA’s FY 2016. Among these projects, all 41 Category A projects and
59 projects selected from Categories B, C and Financial Intermediary (FI) were studied (in total
100 projects) .

The reviewed projects are listed in Table 1-1.

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Table 1-1 List of Reviewed Projects


No. Project Env. Field
Country Project Name Sector
Type Category Survey
1 Uzbekistan Navoi Thermal Power Station ODA Loan Thermal A
Modernization Project power
generation
2 Sri Lanka New Bridge Construction Project over ODA Loan Road & A
the Kelani River bridge
3 Uzbekistan Turakurgan Thermal Power Station ODA Loan Thermal A
Construction Project power
generation
4 Myanmar Thilawa Special Economic Zone Investment Industrial A
(Class-A Area) Development Project 1 Project development
under
Private
Sector
Investment
Finance
(PSIF)
5 India Delhi Mass Rapid Transport System ODA Loan Railway A 
Project Phase 3
6 Bangladesh Dhaka Mass Rapid Transit ODA Loan Railway A
Development Project(1)
7 Bangladesh The Kanchpur, Meghna, and Gumti 2nd ODA Loan Road & A
Bridges Construction and Existing bridge
Bridges Rehabilitation Project
8 Cambodia National Road No. 5 Improvement ODA Loan Road & A
Project(Battambang-Sri Sophorn bridge
Section)
9 Bangladesh Matarbari Ultra Super Critical Coal- ODA Loan Thermal A
Fired Power Project(I) power
generation
10 Philippines Central Luzon Link Expressway Project ODA Loan Road & A
bridge
11 Philippines Pasig-Marikina River Channel ODA Loan River & sand A
Improvement Project(Phase 3) erosion
control
12 Philippines New Bohol Airport Construction and ODA Loan Airport A
Sustainable Environment Protection
Project
13 Indonesia Indramayu Coal Fired Power Plant ODA Loan Thermal A 
Project (E/S) power
generation
14 Mozambique Mandimba-Lichinga Road Upgrading ODA Loan Road & A
Project bridge
15 Egypt Greater Cairo Metro Line No.4 Phase 1 ODA Loan Railway A
Project
16 Vanuatu Port Vila Lapetasi International Wharf ODA Loan Port A
Development Project
17 Viet Nam Hanoi City Ring Road No.3 ODA Loan Road & A
Construction Project (Mai Dich - bridge
South Thang Long Section)
18 Cambodia National Road No.5 Improvement ODA Loan Road & A
Project (Prek Kdam - Thlea Ma'am bridge
Section )(I)
19 Tunisia Rades Combined Cycle Power Plant ODA Loan Thermal A
Construction Project power
generation
20 El Salvador San Miguel Bypass Construction ODA Loan Road & A
Project bridge

1
In this report, “Class A”, which comes from the project name at the time of signing agreement document, is used for the
project name; however, the name ‘Zone A’ had become generalized among the concerned parties, and now the site is also
called ‘Zone A’.

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No. Project Env. Field


Country Project Name Sector
Type Category Survey
21 Cambodia National Road No.5 Improvement ODA Loan Road & A
Project(Thlea Ma'am-Battambang and bridge
Sri Sophorn-Poipet Sections)(I)
22 Ukraine Bortnychi Sewage Treatment Plant ODA Loan Waste A
Modernization Project management
23 Bangladesh Jamuna Railway Bridge Construction ODA Loan Railway A
Project(E/S)
24 Viet Nam North-South Expressway Construction ODA Loan Road & A 
Project (Ben Luc - Long Thanh Section) bridge
25 Uzbekistan Electric Power Sector Capacity ODA Loan Thermal C
Development Project power
generation
26 India Mumbai Metro Line 3 Project ODA Loan Railway A
27 Philippines Flood Risk Management Project for ODA Loan River & sand A
Cagayan de Oro River erosion
control
28 Cameroon Batchenga - Lena Road Project ODA Loan Road & A
bridge
29 India Rengali Irrigation Project(Phase 2) ODA Loan Agriculture A
30 Philippines North - South Commuter Railway ODA Loan Railway A
Project (Malolos- Tutuban)
31 India Ahmedabad Metro Project (I) ODA Loan Railway A
32 India North East Road Network Connectivity ODA Loan Road & A
Improvement Project (Phase 1) (I) bridge
33 India Mumbai Trans-Harbour Link Project ODA Loan Road & A
(I) bridge
34 Indonesia Engineering Services (E/S) for ODA Loan Railway A
Construction of Jakarta Mass Rapid
Transit East-West Line Project (Phase I)
35 Kenya Olkaria V Geothermal Power ODA Loan Thermal A
Development Project power
generation
36 Myanmar Infrastructure Development Project in ODA Loan Industrial B 
Thilawa Area Phase I development
37 Viet Nam Rental Factory Development Project for Investment Industrial B 
SMEs Project development
under PSIF
38 South Sudan The Project for Construction of Nile Grant Aid Road & A
River Bridge bridge
39 Cambodia The Project for the Study on Technical Port A
Strengthening Competitiveness and Cooperation
Development of Sihanoukville Port (Master
Plan)
40 Paraguay The Project for Study on Integrated Technical Agriculture A
Development of the Adjacent Zones to Cooperation
the Yacyreta Dam Reservoir (Master
Plan)
41 Costa Rica Las Pailas II Geothermal Project ODA Loan Thermal A 
(Guanacaste Geothermal Development power
Sector Loan) generation
42 Tanzania Kenya-Tanzania Power Interconnection ODA Loan Power A 
Project
43 Latin Latin America and Caribbean Investment Power FI 
American Sustainable Energy Project Project
and under PSIF
Caribbean
countries
44 India Joint Feasibility Study for Mumbai- Technical Railway A
Ahmedabad High Speed Railway Cooperation
Corridor (Master
Plan)

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No. Project Env. Field


Country Project Name Sector
Type Category Survey
45 Uganda The Project on Irrigation Scheme Technical Agriculture A
Development in Central and Eastern Cooperation
Uganda (Master
Plan)
46 Sri Lanka Major Bridges Construction Project of ODA Loan Road & B
the National Road Network bridge
47 Cabo Verde Water Supply System Development ODA Loan Water supply B
Project in Santiago Island
48 Laos Southern Region Power System ODA Loan Power B
Development Project
49 Myanmar Greater Yangon Water Supply ODA Loan Water supply B
Improvement Project
50 Cote d'Ivoire Abidjan Port Cereal Berth Construction ODA Loan Port B
Project
51 Egypt Borg El Arab International Airport ODA Loan Airport B
Extension Project
52 Bangladesh Natural Gas Efficiency Project ODA Loan Thermal B
power
generation
53 Panama Urban Transportation Line-3 ODA Loan Railway B
Development Project (1)
54 Indonesia Bali Beach Conservation Project (Phase ODA Loan Beach B
2) conservation
55 Indonesia Metropolitan Sanitation Management ODA Loan Sewage B
Investment Program: Engineering
Service for Sewerage System
Development in DKI Jakarta
56 Viet Nam Second Transport Sector Loan for ODA Loan Road & FI
National Road Network Improvement bridge
57 Bangladesh Maternal, Neonatal and Child Health ODA Loan Sanitation FI
(MNCH) and Health System
Improvement Project
58 Philippines Harnessing Agribusiness Opportunities ODA Loan Agriculture FI
through Robust and Vibrant
Entrepreneurship Supportive of
Peaceful Transformation
59 Indonesia Rural Settlement Infrastructure and ODA Loan Poverty FI
Kabupaten Strategic Area Reduction
60 African Private Sector Assistance Loan under ODA Loan Private sector FI
Development the Joint Initiative titled EPSA for assistance
Bank (AfDB) Africa VI
61 Egypt Hurghada Photovoltaic Power Plant ODA Loan Power C
Project
62 Cambodia The Project for Flood Disaster Grant Aid Disaster B
Rehabilitation and Mitigation prevention
63 Palestine The Project for the Improvement of Grant Aid Waste C
Solid Waste Management in the West management
Bank
64 Laos Mini-Hydropower Development Project Grant Aid Power B
65 Paraguay el Proyecto de Mejoramiento del Grant Aid Water supply B
Sistema de Suministro de Agua en
Coronel Oviedo
66 Tajikistan The Project for Improvement of Grant Aid Airport B
Dushanbe International Airport
67 Kyrgyzstan The Project for Avalanche Protection on Grant Aid Road & B
Bishkek-Osh Road bridge
68 Bangladesh Poverty Reduction Efforts Grant Aid Education B
69 Papua New The Project for Reconstruction of Grant Aid Road & B
Guinea Bridges on New Britain Highway bridge
70 Solomon The Project for Upgrading of Kukum Grant Aid Road & B
Islands Highway bridge

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JICA Study for Review of JICA Guidelines for Environmental and Social Considerations February 2020

No. Project Env. Field


Country Project Name Sector
Type Category Survey
71 Morocco The Project for Construction of Grant Aid Fishery B
Shellfish Aquaculture Technology
Research Center
72 Ghana The Project for Reinforcement of Power Grant Aid Power B
Supply to Accra Central
73 Uganda The Project for Improvement of Gulu Grant Aid Road & B
Municipal Council Roads in Northern bridge
Uganda
74 Nepal The Program for Rehabilitation and Grant Aid Disaster B
Recovery from Nepal Earthquake recovery
75 Mauritania The Project for the Expansion of Grant Aid Port B
Fishing Port in Nouadhibou
76 Afghanistan The Project for Strengthening Security Grant Aid Airport B
in Kabul International Airport
77 Cambodia The Project for Expansion of Water Grant Aid Water supply B
Supply System in Kampot
78 Senegal le Projet de Réhabilitation du Môle 3 du Grant Aid Port B
Port de Dakar
79 Kenya The Project for Augmentation of Water Grant Aid Water supply B
Supply System in Narok
80 Rwanda The Project for Rehabilitation of Grant Aid Agriculture B
Irrigation Facilities in Rwamagana
District
81 Philippines The Programme for Rehabilitation and Grant Aid Disaster FI
Recovery from Typhoon Yolanda recovery
82 Nigeria The Project for Emergency Grant Aid Power C
Improvement of Electricity Supply
Facilities in Abuja
83 Mozambique Support for Agricultural Development Technical Agriculture B
Master Plan for Nacala Corridor in Cooperation
Mozambique (Master
Plan)
84 Angola The Project for Power Development Technical Power B
Master Plan Cooperation
(Master
Plan)
85 Jordan Project for formulating Water Supply Technical Water supply B
Plan for the Host Communities of Cooperation
Syrian Refugees (Master
Plan)
86 El Salvador The Project for Capacity Development Technical Climate B
of the Department of Climate Change Cooperation change
Adaptation and Strategic Risk
Management for Strengthening of
Public Infrastructure, Phase 2
87 Bangladesh Capacity Development Project for Technical Water Supply B
Participatory Water Resources Cooperation
Management through Integrated Rural
Development
88 Gabon The Project for Establishment of Technical Sanitation B
Laboratory Surveillance System for Cooperation
Viral Diseases of Public Health
Concern
89 Namibia Northern Crop and Livestock Technical Agriculture C
Development Master Plan Study Cooperation
(Master
Plan)
90 Thailand Project for Strengthening Institutional Technical Climate C
Capacity for the Implementation of Cooperation change
Bangkok Master Plan on Climate
Change 2013-2023
91 Mongolia Project for Improvement for Planning Technical Urban C
and Implementation Skills of Cooperation planning

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No. Project Env. Field


Country Project Name Sector
Type Category Survey
Ulaanbaatar Master Plan
92 Thailand Feasibility Survey for Appropriate SME Waste B
Medical Waste Disposals by Next- Promotion management
Generation Incinerators under PSIF
93 Viet Nam Feasibility Survey for logistics services SME Port B
for the Cai Mep port activation Promotion
under PSIF
94 Viet Nam Pilot Survey for Disseminating Small SME Hazardous B
and Medium Enterprises Technologies Promotion material
for SF Double Shell Tank for Avoiding under PSIF
Leakage of Hazardous Objects
95 Sri Lanka Verification Survey with the Private SME Waste B
Sector for Disseminating Japanese Promotion management
Technologies for Recycling Project of under PSIF
Organic Garbage and Agricultural
Waste by Screw Type Composting Plant
96 Indonesia Pilot Survey for Disseminating SME's SME Disaster C
Technologies for Disaster Prevention Promotion prevention
and Environmental Regeneration under PSIF
97 Myanmar Verification Survey with the Private SME Transportation C
Sector for Disseminating Japanese Promotion
Technologies for a Container Barge for under PSIF
Shallow Water on Ayeyarwaddy River
98 Zambia Collaboration Program with the Private Others Sanitation B
Sector for Disseminating Japanese under PSIF
Technologies for KANSAI Anti
Mosquito and SHIQUY Anti-Microbial
Paints
99 Indonesia Preparatory Survey on BOP Business Others Livestock B
on Egg Farming and Sales Marketing under PSIF
100 Tonga Collaboration Program with the Private Others Power C
Sector for Disseminating Japanese under PSIF
Technologies for the Natural Disaster
Proof Okinawan Tiltable Wind Turbine
System
Note: BOP: Base of the Economic Pyramid; ODA: Official Development Aid; and SME: Small and Medium-sized
Enterprise
Source:JICA Study Team

Out of 100 reviewed projects, field surveys were conducted on 8 projects. The target projects were
determined based on the relevance to survey items, categories, number of projects by country/region,
project progress, assistance schemes, and sectors as shown Table 1-2.

Selection Criteria:

1. Projects with large scale of involuntary resettlement;


2. Projects located in or near the protected areas;
3. Projects which received enquiries from the stakeholders;
4. Projects in the construction or operation stage;
5. Private Sector Investment Finance projects; and
6. Co-financed projects.

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Table 1-2 Field Surveys Conducted for 8 Projects


Env. Relevant
Country Scheme Project Name
Category Criteria
Myanmar ODA Loan B No.36 Infrastructure Development Project in Thilawa Area Phase 3, 4
I
India ODA Loan A No.05 Delhi Mass Rapid Transport System Project Phase 3 1, 4
Viet Nam ODA Loan A No.24 North-South Expressway Construction Project (Ben Luc - 1, 2, 4, 6
(Co- Long Thanh Section)
financing
with ADB)
Investment B No.37 Rental Factory Development Project for SMEs 4, 5
under PSIF
Indonesia ODA Loan A No.13 Indramayu Coal Fired Power Plant Project (E/S) 3
Costa ODA Loan A No.41 Las Pailas II Geothermal Project (Guanacaste Geothermal 2, 4, 6
Rica Development Sector Loan)
Investment FI No.43 Latin America and Caribbean Sustainable Energy Project 4, 5, 6
under PSIF (one of subprojects in Costa Rica was reviewed)
Tanzania ODA Loan A No.42 Kenya-Tanzania Power Interconnection Project 1, 2, 4, 6
(Co-
financing
with AfDB)
Source:JICA Study Team
A total of 5 projects were selected from Asia, namely Indonesia, Myanmar, Viet Nam (2 projects)
and India; and a total of 3 projects from Africa, Latin America and the Middle East, namely Tanzania
and Costa Rica (2 projects).

Projects which proceeded to the Objection Procedures based on the JICA GL were not subject to
field survey, however, a desk review was conducted with the existing investigation reports prepared
by the Examiners during the Objection Procedures, environmental review documents (a part of the
project appraisal documents) and environmental and social monitoring reports.

1.4 Study Methodology

The methodology of the review study was as follows:

1. The survey items on environmental and social considerations were presented by JICA to the
Advisory Committee, and comments given in the Advisory Committee for Environmental and
Social Considerations on September 1 and October 13, 2017 were incorporated in the survey
items shown in Table 1-3;

2. The safeguard practices of the target projects were studied from the viewpoint of for various
review survey items listed in Table 1-3, and the draft review results sheet for each project was
prepared based on the findings;

3. Separately, changes in the external and internal conditions surrounding the JICA GL were
studied by literature review of relevant Japanese government public documents and the SGPs
of Multilateral Development Banks (MDBs); and

4. Study findings and collected information through above-mentioned 2 and 3 were analyzed to
identify draft discussion points for further considerations on the revision of the JICA GL.

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Table 1-3 Review Survey Item Sheet

Items of Current JICA Survey Items Reference: Results of Reexamining its JICA
GL GL Operation (April 2015)
Preface
1. Basic Matters
1.1 Policy  Summarize the Japanese Government’s
1.2 Objectives policies such as “Cabinet decision on the
1.3 Definitions Development Cooperation Charter” and
1.4 Basic Principles trend of international development such
Regarding as SDGs.
Environmental and
Social Considerations
1.5 Responsibility of  Confirm the responsibility of other
JICA donors such as International Finance
Corporation (IFC), Asian Development
Bank (ADB), etc. for their investment
project financing.
1.6 Requirements of (To be confirmed through the review for
project proponents etc. Appendix 1 of JICA GL)
1.7 Covered Schemes  Summarize JICA’s cooperation project Recommendation from the 3rd working
schemes such as Private Sector group (WG) meeting for reexamination of
Investment Finance (PSIF), SME JICA GL Operation
promotion, etc., which were increased 【Applicability of JICA GL to feasibility
after enforcement of the current JICA study (F/S) and other study for Public
GL. Private Partnership (PPP) projects】
 Summarize change of the business  As for the Preparatory Survey for PPP
environment such as promotion and infrastructure project and SME
speedup of infrastructure export, increase promotion assistance for overseas
of co-financing with international investment, summarize the scheme
financial institutions, etc., after contents and its relevance to the JICA
enforcement of the current JICA GL. GL.
 To clearly mention that the SME
promotion survey is not subject to the
JICA GL in practice since the main
purpose of the survey is to collect the
information. In addition, as for the
SME feasibility survey and the
verification survey, to clearly indicate
that the projects that would have
significant negative environmental and
social impacts, that means Category A
projects, will not be implemented.
1.8 Measures Taken in  Summarize cases which applied Recommendation from the 9th WG meeting
an Emergency “measures taken in an emergency” for reexamination of JICA GL Operation
(Categorization, judgement criteria of 【Confirmation of environmental and social
“emergency,” measure on involvement of considerations in case of emergency】
the advisory committee, information  It is desirable that Category A projects
disclosure, monitoring, follow-up are not applicable to “Emergency
activity, etc.) Measures” described in Section 1.8
under the JICA GL unless life-saving
or humanitarian assistance is urgently
needed.
 In the section 1.8 of the JICA GL, it is
stated that “an emergency means a case
that must be dealt with immediately,
such as restoration after natural
disasters or post-conflict restoration,
when it is clear that there is no time to
follow the procedures of
environmental and social
considerations mentioned in the
guidelines”. It is desirable that
classification criteria are clarified by

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Items of Current JICA Survey Items Reference: Results of Reexamining its JICA
GL GL Operation (April 2015)
describing which projects were
classified as emergency projects so far.
 In the past operation, Section 1.8 of the
JICA GL has been applied to the
Technical Cooperation (Master Plan:
M/P) projects for natural disasters. In
case that it is applied to the other
project scheme, it is desirable to
explain the procedure to be
implemented to the Advisory
Committee.
 If environmental and social
considerations are simplified for an
emergency response, post-project
monitoring or any follow-up measure
needs to be taken appropriately.
1.9 Dissemination  Summarize records which JICA
explained about the JICA GL to project
proponents etc. and its contents.
1.10 Advisory - (To be confirmed through the review for “2.7
Committee of Advice of the Advisory Committee for
Environmental and Environmental and Social Considerations”)
Social Considerations
2. Process of Environmental and Social Considerations
2.1 Information  Confirm status of information disclosure
Disclosure by JICA (Categorization, final report,
environmental and social considerations
reports, results of environmental review,
monitoring result)
 Confirm status of information disclosure
by project proponent etc. (Disclosure
place, term, language, etc. on
environmental and social consideration
reports and monitoring results)
 Confirm status which JICA encouraged
project proponents etc. to disclose the
information.
 Confirm if the third party requested
information disclosure and its
correspondence
 Confirm correspondence to the
information which is prohibited to
disclose
2.2 Categorization  Summarize results of environmental
categorization and its reason.
 Summarize the recategorized project and
its reason
 Summarize categorization justification in
case there was a doubt on the
categorization from the third party.
 Confirm the submission status of the
screening format.
2.3 Impacts to be (To be confirmed through the review for
assessed Appendix 1 of the JICA GL.)
2.4 Consultation with  Confirm records of consultation between
Local Stakeholders JICA and project proponents etc.
 (Record of consultation other than the
above will be confirmed through the
review of Appendix1, Social
Acceptability of the JICA GL.)
2.5 Concern about  Confirm any special consideration on
Social Environment information disclosure and consultation
and Human Rights with local stakeholders taken for

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Items of Current JICA Survey Items Reference: Results of Reexamining its JICA
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cooperation projects in the countries and
areas affected by conflict or where basic
freedoms, including freedom of
expression and the right to receive legal
remedy, are restricted.
 Confirm any special attention paid to
human rights of socially vulnerable
groups
2.6 Laws, Regulations  Whether national legislation on
and Standards of Environmental Impact Assessment (EIA)
Reference and Resettlement Action Plan (RAP) are
complied.
 Whether there is any gap between
projects and the international standards
such as WB SGP.
 Summarize the changes from WB SGP
(Operation Policies: OPs) to ESF.
 Summarize the gap between WB ESF
and the current JICA GL
 Summarize the standards and good
practices in the safeguard policies of
ADB and IFC which can be referred by
JICA projects.
2.7 Advice of  Summarize records of advisory
Advisory Committee committee meetings. (including
for Environmental and improvements in its operation and
Social Considerations information disclosure.)
 Confirm how advices from the advisory
committee at the environmental review
stage were incorporated in the projects.
2.8 Decision-making  Confirm the status of agreement
by JICA documents.
 Whether any cooperation project was
suspended based on agreement
documents.
2.9 Ensuring - (To be confirmed separately through the
Appropriate review of objection procedures.)
Implementation of and
Compliance with the
Guidelines
2.10 Implementation Not applicable.
and Review of the
Guidelines
3. Procedures of Environmental and Social Considerations
3.1 Preparatory Study  Summarize practices of alternative Recommendation from the 5th WG meeting
analyses including “without project” for reexamination of JICA GL Operation
scenarios 【Alternative analysis】
 Confirm implementation records of each  It is necessary to clarify interpretations
procedure in the preparatory study, such of “without project” scenarios under
as scoping, EIA/Initial Environment the JICA GL.
Examination (IEE) study, information
disclosure, stakeholder meetings etc.
3.2 Loan Aid, Grant  Confirm implementation of Recommendation from the 11th working
Aid (excluding environmental review and information group meeting for reexamination of JICA
projects executed disclosure in accordance with GL Operation
through international categorization. 【E/S loan projects】
organizations) and - Preparation of the environmental checklist  If the project falls under para 2 of
Technical Cooperation - Approval and disclosure of EIA, Section 3.2.1. (5) “Engineering Service
Projects Environmental Clearance Certificate (ECC), Loan” in the JICA GL, instead of
RAP and Indigenous Peoples Plan (IPP) and consulting with the Advisory
disclosure Committee for the first time at the
- In case cooperation projects fall under environmental review stage, there
category Financial Intermediary (FI), should be an opportunity to discuss at

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Items of Current JICA Survey Items Reference: Results of Reexamining its JICA
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confirmation records of FI’s capacity on the Advisory Committee meeting from
environmental and social considerations, and the earlier stage, namely the scoping
records of environmental review for category stage of environmental and social
“A “sub-projects (if any) considerations which are conducted by
 In case of Engineering Service (E/S) loan project proponents etc. in the E/S loan
projects, summarize the records of project.
environmental review.
 In case of E/S loan projects, confirm
status of environmental and social
considerations by project proponents etc.
during the E/S stage
 Confirm status of receipt and disclosure
of monitoring results.
 Confirm correspondence to a request on
disclosure of monitoring results from the
third party.
 Confirm if there was any differences
between environmental review results
and monitoring results and its reason
(e.g. a need for more detailed
descriptions in the JICA GL, an
interpretation problem of the JICA GL, a
capability/manpower/resource problem,
etc.).
 Any project which JICA requested
project proponents etc. to take
appropriate actions in accordance with
agreement documents and suspend loan
disbursement (if any).
 Confirm whether the JICA’s procedure
for the project with significant changes
was applied.
3.3 Preliminary  Whether JICA recommended the
Studies of Grant Aid Ministry of Foreign Affairs (MOFA) to
undertaken by MOFA suspend the cooperation project.
3.4 Technical  Confirm implementation of Recommendation from the 5th WG meeting
Cooperation for environmental and social considerations for reexamination of JICA GL Operation
Development Planning procedures at each stage in accordance 【Strategic Environment Assessment (SEA)】
with categorization  It is necessary to consider how to
- Screening conduct the stakeholder meeting at the
- Scoping SEA stage.
- Consultation between JICA and project  It should be noted that EIA will be
proponents etc. implemented at the project level in
- Information disclosure of agreement consideration of the contents of the
documents and/or reports study, consultation records and
 Confirm implementation record of information at the SEA stage. (i.e.
stakeholder meetings during SEA stage. utilization of previous evaluation
 Experience which unexpected results, “Tiering”)
environmental and social impacts were
caused after completion of Technical
Cooperation for Development Planning,
and its correspondence.
Appendix
Appendix 1.  Confirm methodology for quantifying Recommendation from the 8th working
Environmental and cost and benefit related to environmental group meeting for reexamination of JICA
Social Considerations and social considerations in Japan and GL Operation
Required for Intended other donors. 【Environmental and social costs and benefits
Projects  Confirm methodology for environmental in project evaluation】
impact assessment of disasters in Japan  Generally, it is said that quantification
and other donors. of environmental and social costs and
benefits has challenges in the scope
and methodology. However, it is
important to have a common

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Items of Current JICA Survey Items Reference: Results of Reexamining its JICA
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understanding in the Advisory
Committee on to what extent and how
this quantification needs to be handled
in JICA's cooperation projects.
 On the other hand, it is desirable to
consider the following points when
examining the specific approach in the
future, taking into consideration the
JICA GL which say, “to endeavor to
include an analysis of environmental
and social costs and benefits in the
most quantitative terms possible”.
 For the environmental and social costs
and benefits, it is also necessary to
consider the quantification of costs,
while quantification of benefits has
been discussed in the past.
 Additionally, it is important to consider
the necessity of "quantitative
evaluation" and "economic evaluation"
related to environment and society.
 It is good to note that “internalization
of various environmental and social
costs associated with development into
development costs" is not limited to
the quantification of environmental
and social costs and benefits at the
study phase, and it could be broadly
applied to the operation stage by
including mitigation measures in the
Environmental Management Plan
(EMP).
 It is desirable to refer to other aid
agencies’ practices (e.g. by reviewing
the WB’s appraisal documents and
other documents)
 With regard to quantification of
environmental and social costs and
benefits, it is necessary to discuss
specifically by accumulating actual
practices in the projects.

Recommendation from the 7th WG meeting


for reexamination of JICA GL Operation
【Impacts of a disaster on the project and
responses to accidents at the operation stage】
 JICA has proposed, “since disasters
such as earthquakes are different from
environmental and social impacts
caused by the project, it is considered
that disasters are not subject to the
EIA.” However, it is not desirable to
exclude disasters from the scope of
“environmental impact assessment”
because the following cases may be
considered.
 Cases that the project lowers the
resilience of the project site and
increases disaster risks;
 Cases that the project may directly
trigger disasters (e.g. construction
of a dam might induce
earthquakes); and

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Items of Current JICA Survey Items Reference: Results of Reexamining its JICA
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 Cases that the project may
indirectly trigger disasters (e.g.
construction of a power plant
might contribute to global
warming).
 If the cases above are subject to EIA, it
should be discussed either of the
following two ways is appropriate: to
add “disaster” as an item of
environmental and social
considerations, or to evaluate for
disasters in the environmental existing
checklists of the JICA GL (i.e.
geography, geology, etc.), which needs
to be discussed.
 If the cases above are subject to EIA,
the responsible agency of disaster
prevention such as earthquakes should
be clarified at the construction and
operation stages in addition to the
detailed design (D/D) stage (same as
the responsible agency for accident
prevention).
 It is desirable to define and
differentiate the concept of disasters
and accidents.
Underlying Principles  Confirm status of investigation and
examination on environmental and social
impacts at the planning stage.
 Confirm status of examination on
alternatives and mitigation measures to
avoid and minimize environmental and
social impacts.
 Confirm if the above-mentioned
examination results were reflected in the
project plan.
 Confirm if costs and benefits related to
environmental and social considerations
were tried to be evaluated quantitatively
and evaluated qualitatively.
 Confirm if costs and benefits related to
environmental and social considerations
were closely harmonized with economic,
financial, institutional, social and
technical analyses of the project.
 Confirm if results of environmental and
social considerations study including
examination on alternatives and
mitigation measures were specified in a
separate document or part of other
documents.
 Confirm if an environmental impact
assessment report was prepared for
projects especially with significant
environmental and social impacts.
 Confirm if experts committee was
established for projects with especially
significant environmental and social
impacts and arguable projects.
Examination of  Confirm if appropriate plan and structure
Measures for follow-ups, such as environmental
management plan and monitoring plan
are prepared, and its cost and

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Items of Current JICA Survey Items Reference: Results of Reexamining its JICA
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procurement method are examined.
 (Other items will be confirmed through
the review of Section 2.8.)
Scope of Impacts to  Confirm if appropriate scoping was fully Recommendation from the 4th WG meeting
Be Assessed conducted as per the JICA GL. for reexamination of JICA GL Operation
 Confirm if the amount of Green House 【Climate change】
Gas (GHG) emission by the project was  Although there are some challenges on
calculated and evaluated. climate change which are beyond the
 Confirm practices of multilateral and scope of reexamination of JICA GL
bilateral donors on climate change (GHG operations, the following points can be
emission) and pollution control considered as the issues to be
 Summarize practices on examination and discussed in the future.
assessment of derivative, secondary, and  The overall carbon management
cumulative impacts as well as the strategy of JICA needs to be
impacts of indivisible projects clarified at the earliest.
 Summarize practice of WB, ADB and  Not only for projects in which is
IFC on examination and assessment of expected to reduce GHG
derivative, secondary, and cumulative emissions, but also for projects in
impacts as well as the impacts of which would not reduce GHG
indivisible projects. emissions, GHG emissions should
be calculated to grasp total GHG
emissions from entire JICA
projects.
 The impacts of climate change
should be evaluated by
measurement of emissions, not by
emission reduction.
 As environmental items for scoping,
“climate change (GHG emission)” is
suitable rather than “global warming.”
 In order to grasp the GHG emissions
from the entire JICA projects, it is
suggested that in principle, GHG
emissions during the construction
phase should be also evaluated, except
only the case where the GHG
emissions are particularly negligible
compared to the operation phase.
 It is desired that the assessment of
GHG emissions for the supply chain is
also taken into consideration in the
future. For example, as for large-scale
development projects of the road or
railway sector, it is assumed that a
large amount of CO2 is generated at
the time of production of cement.
Therefore, it is necessary to consider
whether (1) evaluation of GHG
emissions associated with production
of the raw materials and (2)
management and recording of cement
consumption could be required.

Recommendation from the 5th working


group meeting for reexamination of JICA
GL Operation
【Climate change】
 As for climate change (GHG
emissions) at the scoping stage, a
baseline is set in accordance with a
certain methodology such as JICA's
Climate Finance Impact Tool for
Mitigation (JICA Climate FIT

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Items of Current JICA Survey Items Reference: Results of Reexamining its JICA
GL GL Operation (April 2015)
(Mitigation)), and the mitigation effect
is evaluated by comparing with that
baseline. However, just like other
impact items, it might be possible to
evaluate the impact of climate change
(GHG emissions), compared with the
current status as a reference point.

Recommendation from the 1st WG meeting


for reexamination of JICA GL Operation
【Indivisible Projects】
 Regarding the scope of “the extent that
is reasonably predictable”, it is
necessary to clarify it by accumulating
precedents.
 In dealing with the indivisible projects,
it should be clearly stated that
“appropriate environmental and social
considerations documents” of the
indivisible projects means that JICA
needs to confirm whether
environmental and social
considerations documents of the
indivisible projects comply with the
JICA GL.
 Although “the indivisible projects” are
specified as one of the "Impacts to be
assessed" in the JICA GL, it seems
somewhat difficult to study and
consider the impacts of the indivisible
projects which are not financed by
JICA.
 In order to clarify the contents of “the
indivisible projects”, major
examples/precedents should be
presented.
 Since it is necessary to mention that
there are various “indivisible projects,”
these examples should be described in
the Frequently Asked Questions (FAQ)
of the JICA GL in the future.

【Derivative impacts, secondary impacts】


 Regarding the scope of “the extent that
is reasonably predictable”, it is
necessary to clarify it by accumulating
precedents.
 IFC Performance Standards (IFC PS)
defines them as “(ii) impacts from
unplanned but predictable
developments caused by the project
that may occur later or at a different
location; or (iii) indirect project
impacts on biodiversity or on
ecosystem services upon which
Affected Communities’ livelihoods are
dependent.”. As for (iii), only the
impact on the ecosystem is discussed,
giving an impression that the impact
on the social aspect is not considered.
Therefore, (iii) should be deleted to
avoid misunderstanding, if the social
aspect is also considered in (ii).

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Items of Current JICA Survey Items Reference: Results of Reexamining its JICA
GL GL Operation (April 2015)
 In order to clarify the contents of
“derivative and secondary impacts”,
major examples/precedents should be
presented.
 Whether the project has “derivative
and secondary impacts” and its
contents should be explained to the
advisory committee in the early stage
by utilizing the opportunity when the
project summary is explained at the
general meeting of the advisory
committee.
 “Unplanned but predictable
development” includes a wide range of
factors including expansion.

【Cumulative impacts】
 Regarding the scope of “the extent that
is reasonably predictable”, it is
necessary to clarify it by accumulating
precedents.
 In order to make the contents of
"cumulative impacts" clearer, the
major examples/precedents should be
presented.
 There are various international
discussions on "cumulative impacts",
so there is no need to rush to define the
definition and scope, but to reconsider
them based on international trends.
 Whether the project has “cumulative
impacts” should be explained in the
early stage by utilizing the opportunity
when the project summary is explained
at the general meeting of the advisory
committee.
 The “cumulative impact” should
include impacts of “individuals’
activities”.
Compliance with  Summarize cases of which project area Recommendation from the 2nd and 6th WG
Laws, Standards, and was in “protected areas that are meeting for reexamination of JICA GL
Plans specifically designated for the Operation
conservation of nature or cultural 【Protected areas specifically designated by
heritage.” laws or ordinances for the conservation of
 Summarize practice of WB, ADB and nature or cultural heritage】
IFC on cases of which project area was  As the FAQ of the JICA GL explains
in “protected areas that are specifically the "conditions" to be "specifically
designated for the conservation of nature designated area," it is suggested that
or cultural heritage.” specific examples should be described
 (Other items will be confirmed through in the FAQ for better understanding.
the review of Section 2.6.)  First, the protected areas need to be
identified by the national legislations
of the borrower government. If such a
legislation is not available, it should be
discussed whether International Union
for Conservation of Nature (IUCN)
rules can be applicable. In addition,
whether the protected areas need to be
identified by IUCN rules should be
described.
 Not only the protected areas designated
by the central government’s
legislation, but also the designated

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Items of Current JICA Survey Items Reference: Results of Reexamining its JICA
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areas by the ordinance or others of the
local governments should be
considered as "protected areas".
 It is necessary to judge rationally
whether and to what extent the
protected area can be developed for
each project in accordance with the
conditions specified by the national
legislation of the borrower’s country.

【Project implementation conditions in "area


designated specially for nature protection
and cultural heritage protection"】
 In consideration of the provision,
“[p]rojects must, in principle, be
undertaken outside of protected areas
that are specifically designated by laws
or ordinances for the conservation of
nature or cultural heritage” (hereafter
called the designated area) under the
JICA GL, it is necessary to explain that
in principle, the project
implementation in the designated area
is not envisaged.
 However, it is also important to enable
project formation, if JICA can justify
the background and reasons for
implementing the project in the
designated area.
 Although the JICA GL define the
protected areas mean “the protected
area that are specially designated by
laws or ordinances for the conservation
of nature or cultural heritage”, but it is
necessary to consider that there are
different contents of the laws and
institutions for the protected area
management in countries (For
example, some countries have the
legislation that allows a certain
development in the designated areas,
such as buffer zones or places where
the degree of protection is not high, if
the project meets the criteria).
 There are some issues raised at the
international conferences, etc. that the
borrower government changed the
designated areas so that the project can
be implemented in “the area designated
as such by the country and/or local
governments by laws and/or
ordinances to protect nature and
cultural heritage”. Therefore, it is
necessary to take a careful response
recognizing the issue.
Social Acceptability  Confirmation of records of stakeholder Recommendation from the 4th WG meeting
meetings for reexamination of JICA GL Operation
1) Dates of announcement and implementation 【Stakeholder consultation in consideration
2) Place of socially vulnerable groups】
3) Method of consultation (community  It is suggested to consider more
assemble, individual interview, language) specific measures in conducting
4) Considerations for socially vulnerable stakeholder consultation with socially
groups vulnerable groups as the future agenda

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Items of Current JICA Survey Items Reference: Results of Reexamining its JICA
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5) Method of announcement (following specific points were
6) Participants (the number of people, proposed).
percentage of affected people, affiliation,  To consider a mechanism to bring
gender, etc.) in people who could not attend the
7) Contents of discussions (project area, stakeholder consultation and to
project plan, issues and needs from local explain remaining issues that
residents, etc.) could not discussed in the
8) Comments from participants stakeholder consultation.
9) Reply by project proponents etc.  To set the expected maximum
10) Result of reflection of received comments number of participants per
to the plan and project meeting to ensure meaningful
11) Preparation of Minutes of Meeting participation if the number of
 Confirm if any third party raise an issue stakeholders is large.
on the project in terms of social  To pay attention when
acceptability and its reason (e.g. a need stakeholders who have different
for more detailed descriptions in the interests are invited together
JICA GL, an interpretation problem of because it might fail to elicit frank
the JICA GL, a opinions from stakeholders in such
capability/manpower/resource problem, a situation.
etc.).
 Summarize considerations for socially
vulnerable groups.
Ecosystem and Biota  Summarize practices of the project which Recommendation from the 2nd & 6th
was implemented in the critical natural working group meeting for reexamination of
habitats. (including justification, any JICA GL Operation
projects in the critical natural habitats 【Critical natural habitats】【Natural
other than forests, consideration status on habitats】
biodiversity conservation areas, impact  As for “Critical natural habitats”,
on the local community and impact on specific examples should be described
natural habitat caused by the local for better understanding.
community, impact on social  In the JICA GL, although "critical
environment and impact on natural forests" are listed together with
habitat caused by social environment) "critical natural habitats",
 Summarize practices of the project which environmental and social impacts on
was implemented in accordance with areas other than forests such as the
“conditions of project implementation in “ocean” and “highlands” should also
critical natural habitats” be taken into consideration.
 Summarize practice of WB, ADB and  “Critical natural habitats” are defined
IFC on projects which involves “critical in the “Ecosystems and Biota” in the
natural habitats” and “significant JICA GL; however, it should be
conversion or significant degradation” considered from the aspects of “local
 Confirm if any illegal logging of the communities” and “social
forest was practiced. environment”.
 The “Key Biodiversity Area (KBA)”
which was developed with reference to
the IUCN Red List can be used as a list
showing critical natural habitats.

【Significant conversion and significant


degradation】
 JICA’s interpretation should be taken
into account that “conversion”
represents a negative impact from an
aerial point of view, while
“degradation” represents a negative
impact from a qualitative point of
view.
 As it is specified in the WB's OP 4.04
Annex A, “significant conversion may
include, for example, land clearing;
replacement of natural vegetation,
permanent flooding such as by dam,
drainage, dredging, filling, or

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Items of Current JICA Survey Items Reference: Results of Reexamining its JICA
GL GL Operation (April 2015)
channelization of wetlands, or surface
mining,” some examples should be
described in the FAQ of the JICA GL.
In addition, it includes the "significant
conversion" of "ecosystems not only in
land areas but also in water areas" due
to serious pollution and others.
 It is necessary to judge rationally
whether the project will cause
"significant conversion" or "significant
degradation" from the background and
the contents of each project.

Recommendation from the 6th WG meeting


for reexamination of JICA GL Operation
【Conditions for project implementation in
“Critical natural habitats”】
 In consideration of the stipulation in
the JICA GL that “[p]rojects must not
involve significant conversion or
significant degradation of critical
natural habitats and critical forests”, it
is necessary to explain that in
principle, the project implementation
in the critical natural habitat is not
envisaged.
 However, it needs to be carefully
examined whether the JICA GL have
requirements which make JICA’s
project implementation impossible in
the critical natural habitats in practice.
 It is necessary to carefully examine
whether the JICA GL include
“Endangered species II (Vulnerable:
VU)” and “Near Threatened: NT”
which are classified as per the category
of Japanese Ministry of Environment
in endangered species, in addition to
“Endangered species IA/IB (Critically
Endangered: CR and Endangered:
EN)” as for the JICA GL’s stipulation
of “the list of endangered species in
which projects shall not cause net
reduction over a reasonable period”. It
is important to ensure that the effort of
the study and project does not increase
and practical measures are taken in
implementing mitigation measures and
monitoring.
Involuntary  Confirm preparation and disclosure
Resettlement status of RAP and records of consultation
meetings (including the meeting
contents, language, mode of the
consultation)
 Confirm if involuntary resettlement and
loss of means of livelihood were avoided
and minimized, and effective measures
were taken on agreement with affected
people in documents.
 Confirm the expected number of project
affected people at the environmental
review stage.
 Confirm the number of actual project

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Items of Current JICA Survey Items Reference: Results of Reexamining its JICA
GL GL Operation (April 2015)
affected people at the monitoring stage.
 Contents of compensation at the
environmental review stage. (Timing of
compensation, calculation method of
compensation rate including full
replacement cost, measures for
recovering livelihood and other
supports.)
- (Only for the projects subject to the field
survey)
 Confirm if resettled people have
improved their standards of living,
income opportunities, and production
levels or at least restored these to pre-
project levels.
 Confirm status of establishment of
Grievance Redress Mechanism (GRM).
Indigenous Peoples  Confirm if there were adverse impacts on
indigenous people.
 Confirm if measures to avoid and
minimize adverse impacts were
examined.
 Confirm if indigenous peoples plan was
prepared and disclosed.
 Confirm if Free, Prior and Informed
Consultation/Consent (FPIC) process
was implemented.
Monitoring  Confirm if the monitoring plan was
prepared.
 (Other items will be confirmed through
the review of Section 3.2.)
Appendix 2. EIA  Confirm status of EIA approval,
Reports for Category language, information disclosure in the
A Projects borrower’s country, and permission of
copying
 Confirm if the EIA report includes the
items specified in the JICA GL.
 Confirm whether EIA was prepared for
projects that were categorized as
“Category A” because of large-scale
involuntary resettlement as per the JICA
GL (not due to the expected
environmental impacts).
Appendix 3.  Confirm justification of “Sensitive
Illustrative List of Sectors”
Sensitive Sectors, (especially, the scale of impacts of the
Characteristics, and project in power distribution, water
Areas supply and agriculture sectors which
usually do not have significant negative
impacts if the project does not have
sector-related sensitive characteristics or
located in a sensitive area)
Appendix 4. Screening  (Screening form will be reviewed when
Format the JICA GL are reviewed)
Appendix 5.  (Environmental checklist will be
Categories and Items reviewed when the JICA GL are
in Checklist reviewed)
Appendix 6. Items  Confirm justification of monitoring
Requiring Monitoring items, reference standards, preparation of
the monitoring plan for construction and
operation phases.
Others

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CHAPTER 2 RESULTS OF THE REVIEW STUDY

2.1 Summary of Reviewed Projects

2.1.1 Projects by Region

In order to obtain an overview of the 100 reviewed projects, Figure 2-1 shows the number of projects
by region. The features are as follows.

 100 reviewed projects cover 47 countries in 6 regions.


 By region, there are 38 projects in Southeast Asia and the Pacific, followed by 21 in Africa, 20
in South Asia, 8 in the Middle East and Europe, 7 in Latin America, and 6 in East / Central
Asia.

East and Central Asia:6

Latin America:7

Middle East /
Europe:8 Southeast Asia /
Oseania:38

South Asia: 20

Africa:21

Note: The region includes the following countries: Project No. 43 in Latin American and Caribbean countries project is included in Latin
America, and Project No. 60 co-financed with African Development Bank is included in Africa.

Southeast Asia / Oceania: Indonesia, Cambodia, Solomon Islands, Thailand, Tonga, Vanuatu, Papua New Guinea, Philippines, Viet Nam,
Myanmar, Laos

South Asia: Afghanistan, India, Sri Lanka, Nepal, Bangladesh

Africa: Angola, Uganda, Ghana, Cabo Verde, Gabon, Cameroon, Kenya, Cote d'Ivoire, Zambia, Senegal, Tanzania, Nigeria, Namibia,
South Sudan, Mauritania, Mozambique, Rwanda

Middle East / Europe: Ukraine, Egypt, Tunisia, Palestine, Morocco, Jordan

Latin America: El Salvador, Costa Rica, Panama, Paraguay

East and Central Asia: Uzbekistan, Kyrgyzstan, Tajikistan, Mongolia

Source: Prepared by JICA Study Team

Figure 2-1 Reviewed Projects by Region

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2.1.2 Projects by JICA Project Scheme


Among the 100 reviewed projects, there are 56 Japanese ODA Loan Projects (of which 3 are PSIF
Private-Sector Investment Finance), followed by 22 Grant Aid Projects and 13 Technical
Cooperation Projects (of which 8 are Technical Cooperation for Development Planning). In addition,
there are 6 projects for Verification Survey/Feasibility Survey with the Private Sector for
Disseminating Japanese Technologies, 2 projects for Promoting Private Sector Cooperation and 1
project for BOP Business Collaboration.

2.1.3 Projects by Sector


The number of projects by sector is shown in Figure 2-2. The features are as follows:

 The 100 reviewed projects cover 25 sectors.


 There are 20 projects under the road and bridge sector, 10 projects under the railway sector, 9
projects each under the thermal power and non-thermal power sectors, 7 projects each under
the water supply and agricultural sectors, 6 projects under the port sector, and 4 projects each
in the airport and waste sectors.

Disaster Prevention:2
Disaster Recovery: 2
Climate Change: 2
Others:
River / Roads and
10
ErosionContorol:2 Bridges:20
Health / Sanitation: 3
Industrial
Development: 3 Railways:10
Waste:4

Airport:4
Thermal
Port:6 Power:9

Agriculture:7 Non-thermal
Water:7 Power:9
Source: Prepared by JICA Study Team

Figure 2-2 Number of Reviewed Projects by Sector

2.2 Application results of JICA GL for Environmental and Social Considerations for
100 Reviewed Projects

The JICA GL consist of 3 chapters and 6 appendixes. Chapter 1 Basic Matters, Chapter 2 Process
of Environmental and Social Considerations and Chapter 3 Procedures of Environmental and Social
Considerations discuss the requirements and procedure for JICA, and 6 Appendixes describe

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requirements for project proponents etc. and the project. In this study, project’s environmental and
social performance and their compliance with the JICA GL were reviewed.

2.2.1 Review Results of "I. Basic Matters"

Table 2-1 shows the review results as to “Chapter 1. Basic Matters” in JICA GL.

Table 2-1 Review Results of Survey Item Sheet for “Chapter I. Basic Matters”
Reference
Items in JICA GL Survey Item
Number
1.1 Policy  Summarize the Japanese Government’s policies such as
“Cabinet decision on the Development Cooperation Charter”
1.2 Objectives and trend of international development such as SDGs

1.3 Definitions
1
1.4 Basic Principles
Regarding
Environmental and
Social Considerations
1.5 Responsibility of JICA  Confirm the responsibility of other donors such as IFC, ADB,
2
etc. for their investment project financings.
1.6 Requirement of Project (Review through the Appendix 1)
3
Proponents etc.
1.7 Covered Schemes  Summarize JICA’s cooperation project schemes such as PSIF,
4 SME promotion, etc., which were increased after enforcement
of the current JICA GL.
 Summarize changes in business environment such as
introduction of speedup of infrastructure export, increase of
5
co-financing with international financial institutions, etc., after
enforcement of the current JICA GL).
1.8 Measures Taken in an  Summarize cases to which “measures taken in an emergency”
6
Emergency were applied
1.9 Dissemination  Records of explanation to project proponents etc.
7
1.10 Advisory Committee of (Confirmed through the review for Section 2.7 “Advice of Advisory
Environmental and 8 Committee for Environmental and Social Considerations”)
Social Considerations
Source: Prepared by JICA Study Team

The review results are summarized as follows.

For “1.1 Policy”, “1.2 Objectives”, “1.3 Definitions”, “1.4 Basic Principles Regarding
Environmental and Social Considerations”, “1.5 Responsibility of JICA”, “1.6. Requirements of
Project Proponents etc.”, “1.7 Covered Schemes” and “1.10 Advisory Committee for Environmental
and Social Considerations” stated in “1. Basic Matters” of JICA GL, since those items apply to all
projects equally and not discussed for each individual projects, all of them are compiled in “Chapter
4 Draft Discussion Points for Revision of JICA GL for Environmental and Social Considerations”
of this report.

“1.8 Measures Taken in an Emergency” was taken up as an issue of the WG meeting for
reexamination of JICA GL Operation, and this review investigated how the clause 1.8 “Measures
taken in an emergency” has been implemented. However, none of the review study projects fall
under this category. On the other hand, when the projects other than the reviewed projects were

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taken into consideration, a total of seven projects (Technical Cooperation for Development
Planning) were confirmed to which emergency measures were applied after the enforcement of JICA
GL. In all the projects, the Detailed Planning Survey, in which JICA finalizes the scope of the project
in consultation with project proponents, etc. during JICA team’s mission(s), was skipped. However,
it was confirmed that preliminary scoping (which is usually included in the Detailed Planning
Survey) was carried out in the main JICA study. In all cases, the application of measures taken in
emergency was reported to the Advisory Committee for Environmental and Social Considerations
before the main JICA survey started.

Table 2-2 Projects which Emergency Measures were Applied


Environmental
Project Name Cooperation Scheme
Category
Technical Cooperation
Project for Comprehensive Flood Management Plan for the Chao Phraya River
B for Development
Basin (Thailand)
Planning
Technical Cooperation
Jarar valley and Shebele Sub-basin Water Supply Development Plan, and
B for Development
Emergency Water Supply (Ethiopia)
Planning
Technical Cooperation
The Project for Enhancing Community Resilience against Drought in Northern
B for Development
Kenya (Kenya)
Planning
Technical Cooperation
Rural Resilience Enhancement Project (Ethiopia) B for Development
Planning
Technical Cooperation
Sustainable Smallholder Irrigation Development and Management in Semi-
B for Development
Arid Lands Project (Kenya)
Planning
Technical Cooperation
Project on Rehabilitation and Recovery from Nepal Earthquake (Nepal) B for Development
Planning
Technical Cooperation
Project for Regional Disaster Risk Resilience Plan in Central Sulawesi
B for Development
(Indonesia)
Planning
Source: JICA website

・ As for the “1.9 Dissemination”, it was investigated whether the contents of JICA GL were
explained to project proponents etc., and in all the reviewed projects, it was confirmed that
JICA GL were explained to project proponents etc. at the time of appraisal and they all agreed
on the compliance with JICA GL.

2.2.2 Review Results of "II. Process of Environmental and Social Considerations"

Findings
The findings are summarized as follows.

・ Regarding “2.1 Information Disclosure” of JICA, all the defined relevant materials such as
Category Classification, Preparatory Study Report, Environmental and Social Consideration
Documents (e.g. EIA, RAP, IPP and/or others) are published on JICA's website. (Regarding

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disclosure of the final report, the project for promotion and dissemination of private sector
cooperation was excluded since the project does not carry out a preliminary survey.)
・ Monitoring results disclosure on JICA’s website and in the host countries will be described
later (Please refer to Section 2.2.3 (5).).
・ Regarding the disclosure of environmental and social considerations documents (excluding
monitoring results) in host countries, JICA facilitated project proponents, etc., through the
project formulation stage, to disclose information on environmental and social considerations
of the project to local stakeholders. As for 41 Category A projects, excluding 1 E/S loan project
which environmental and social considerations documents are to be prepared in that project,
and 4 projects for Technical Cooperation for Development Planning, it was confirmed that
environmental and social considerations documents were disclosed in all 36 projects by the
project proponents etc. With regard to disclosure means, these documents are mostly disclosed
at project proponent’s offices or which copies are provided (36 projects), and disclosed on the
project proponent’s website (14 projects). As for the used language, when the main document
is written in English, the executive summary was often prepared in a local language. Regarding
42 Category B projects, most projects had no agreement on disclosure between JICA and
project proponents and etc., or there was no country regulation which requires project
proponents and etc. to prepare environmental and social considerations documents, excluding
4 projects in which the project proponent disclosed their environmental and social documents.
However, when projects consult with stakeholders and environmental and social considerations
documents were prepared for the projects, these documents were disclosed at the stakeholder
meeting.
・ Regarding disclosure of the environmental and social monitoring results in host countries,
environmental monitoring results have been disclosed in 28 out of 29 projects which are in the
monitoring implementation stage and for which project proponents etc. agreed on disclosure
(except Project No. 38 which is suspended due to a security reason in the project site). Social
monitoring results have been disclosed for 9 out of 10 projects which are in the monitoring
implementation stage and for which project proponents etc. agreed on disclosure (expect
Project No. 38 due to the same security reason).
・ For projects that could not reach an agreement on disclosure of safeguard monitoring results,
it is thought that project proponents, etc. did not disclose them mainly due to not being required
to disclose them under the national legislation and policy. However, the increasing number of
projects have reached an agreement on disclosure of monitoring results after the enforcement
of JICA GL since 2010. Out of the projects for which the loan agreement was concluded in
fiscal year (FY) 2010, 4 projects agreed to disclose environmental monitoring results out of 36
projects which were subject to environmental monitoring. On the other hand, 4 projects agreed
with information disclosure of social monitoring out of 15 loan projects which were subject to
social monitoring. In contrast, in FY 2017, 20 projects agreed with disclosure of environmental
monitoring out of 38 projects which are subject to environmental monitoring, and 12 projects
agreed out of 14 projects which are subject to social monitoring.

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・ Among the reviewed projects, two projects (Nos.4, 83) received a request for information
provision from the third party, and they are the projects proceed to the objection procedure
based on the JICA Gl.
・ Regarding handling of information that is prohibited from public disclosure, it was confirmed
that JICA has not disclosed such information mistakenly and obtained the consent from project
proponents etc. in advance when disclosing related information.
・ Regarding “2.2 Category Classification”, no particular discrepancy was identified between
the categorization results and justifications for all the 100 projects.
・ It was confirmed that the environmental categorization result was questioned by the third
parties for Infrastructure Development Project in Thilawa Area Phase I in Myanmar (No.36)
and Support for Agricultural Development Master Plan for Nacala Corridor in Mozambique
(No.83). As for Project No.36, a letter was submitted from NGOs to JICA on May 24, 2013
and August 28, 2017 requesting that the impacts caused by Thilawa Special Economic Zone
(Class-A Area) Development Project in Myanmar (No.4) be taken into consideration when
determining the categorization of Project No. 36 as it is argued to be an associated facility of
Project No. 36. As for Project No.83, NGOs questioned the conclusion of categorization by
JICA, however, JICA recognizes that the Category B was appropriate considering the likely
impacts of priority projects identified in the early stages of the M/P based on the JICA GL.
・ It was confirmed that changes of the environmental categorization have been made in three
projects (Nos. 25, 27, 63). The reasons for the category change are explained in section 2.2.2
(3.1) in detail.
・ Among the reviewed projects, 42 Category B projects consists of 12 loan projects, 18 grant
projects, 3 technical cooperation projects, 3 technical cooperation projects for development
planning, and 6 projects for collaboration with SMEs (verification survey/feasibility survey
with the private sector for disseminating Japanese technologies). For the 9 projects of technical
cooperation and collaboration with SMEs and others, the environmental and social impact was
limited as they are small-scale with dispatching the experts and procurement/installation of
equipment. For the technical cooperation projects for development planning, the project scale
and its environmental and social impact vary but within the limited scale since the M/P is higher
level planning. On the other hand, 12 loan projects under the category B such as road and
airport rehabilitation, the project scale are relatively large with the average project cost at
around 15 billion Yen and the involuntary resettlement occurs in some projects. For 18 grant
projects, the average project cost is around 2.5 billion Yen which is lower than that in the loan
project, therefore, the environmental and social impact is smaller than that in the loan project
in general. Thus, it was seen that the projects under category B include different scales of the
projects with various ranges of the project types, and risks of the environmental impacts.
・ It was confirmed that all the projects were categorized considering relevant information
obtained from project proponents etc., but not necessarily through the screening form
(Appendix 4 of the JICA GL).

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・ "2.3 Impacts to be Assessed"


⇒Investigated together with provisions of JICA GL Appendix 1
・ "2.4 Consultation with Local Stakeholders"
⇒Investigated together with provisions of JICA GL Appendix 1
・ Regarding the “2.5 Concern about Social Environment and Human Rights”, among 100
reviewed projects, no project was found which was implemented in the countries and areas in
conflict or areas where the right to basic freedom (e.g. freedom of expression) and legal
remedies are restricted.
・ According to the Office of the United Nations High Commissioner for Human Rights, etc.,
threats and attacks to persons who advocate for defending human rights are becoming
international concerns.
・ With respect to "2.6 Laws, Regulations and Standards of Reference", an EIA needed to be
approved by an environmental authority for 50 projects, among which 30 projects were
Category A, and 20 projects were Category B.
・ Among the Category B projects, the EIA was approved for 20 projects at the environmental
review stage.
・ Among the Category A projects, it was confirmed that preparation of EIA nor the approval by
authorities were not required under national laws for 7 projects (No.5, 8. 26, 27, 31,32, and 33)
in the host countries. However, environmental and social impacts were assessed and results
were compiled in EIA based on the requirements of the JICA GL in all those projects, and the
EIA is generally endorsed by project proponents etc.
・ Project Nos. 39, 40, 44, 45, all of which were Category A projects, were not in the stage of
asking for EIA approval since they are Technical Cooperation for Development Planning,
which formulates the M/P.
・ No major deviation was seen in all the reviewed projects from the requirements of WB’s SGP
and other international safeguard standards. For 10 projects (Nos.7, 13, 15, 20, 26, 28, 31, 32,
42, 47), it was confirmed that national environmental standards were applied after the review
was conducted if there was no major difference between the national and international
standards. For example, when the Project No.15 confirmed that there was no major difference
between environmental standards of the World Health Organization (WHO) and that of Egypt,
the project applied for the standard of Egypt. In the case of the Project No.17, though there is
no description on the international standards in the EIA, the project confirmed that there is no
large difference between the national standards in Viet Nam and international standards for air
and noise. The environmental ambient and emission standard values commonly referred as
international standard in many projects include the Environment, Health and Safety (EHS)
guidelines (ambient air quality, noise, vibration, wastewater, river water, air emissions), WHO
standard values (air, noise, vibration, water qualities), International Organization for
Standardization (ISO) standard values (vibration), European Union (EU) standard values (air,
exhaust gas, water quality) and the standard value of Japan (noise, vibration, drainage, water
quality, air, Japan Industrial Standard [JIS] vibration). In addition, although it was not

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frequently used, there are some other standards referred as international standards such as
Singapore's standard value for noise, Kenya's environmental standard value (referred in a
project in South Sudan because there is no environmental standard in South Sudan), United
States Environmental Protection Agency (US EPA) standard value for water quality and
guidelines for soil erosion, Food and Agriculture Organization (FAO) standard values for water
quality. Moreover, a port project (No.16) adopted International Maritime Organization (IMO)
Convention for marine spill, 2 projects of the port and coal-fired power projects (Nos.13,16)
adopted MARPOL Legislation for pollution prevention, 1 airport project (No.51) adopted
International Civil For Aviation Organization standard values for noise, 1 high-speed railway
project (No.25) adopted the vibration standard values of Austria, Germany, Italy, Japan,
Netherlands-Norway, Sweden, the United Kingdom, and the United States. For the involuntary
resettlement, the WB’s OP4.12 and ADB Safeguard Policy Statement (SPS) were referenced
in most projects.
・ Regarding “2.7 Advice of Advisory Committee for Environmental and Social
Considerations”, it was confirmed that the Advisory Committee meetings were properly held
for all 41 Category A projects.
⇒ JICA’s responses to the advices by the Advisory Committee for each project are
described in detail in Section 2.2.2(4).
・ For all the 100 projects, the agreements were concluded between JICA and project proponents
etc.
・ There were no cases confirmed in which the cooperation project was canceled due to non-
compliance of agreement with JICA.

Handling the Information that is prohibited from public disclosure


For all the projects, the relevant information was disclosed based on the consent with the
government and related agencies of host countries. Information that is prohibited from public
disclosure was not disclosed mistakenly.
Environmental Categorization
(3.1) Change of Environmental Categorization
Among the reviewed 100 projects, the environmental categorization was changed for 3 projects
(Nos.25,27,63). In the case of Project No.25, it was categorized as Category A at the initial stage of
project preparation; however, the Engineering Services (hereinafter referred to as E/S) of the power
plant component was scoped out after the environmental review, which led the change of
categorization (from A to C). In the case of Project No.27, the category was changed from B to A as
large-scale resettlement became involved based on the M/P and F/S which have been re-conducted
after the flood damage caused by the typhoon which took place after F/S was conducted by the
project proponent. In the case of Project No.63, the category was changed from B to C since
construction of the final waste disposal site was excluded from the project scope.

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(3.2) Categorization of Technical Cooperation of Development Planning


Out of 100 reviewed projects, 8 Technical Cooperation for Development Planning projects were
included; 4 Category A, 3 Category B, and 1 Category C projects. As for the corresponding sectors,
4 projects belong to the agricultural sector including the large-scale irrigation development and 1
project each for port, railway, power and water supply sectors.
Responses to Advices from the Advisory Committee
・ As of November 2018, the Advisory Committee meetings were held for 41 projects and 557
pieces of advice were given in total. With respects to 550 out of 557 advice, the preparatory
study reports were revised following them (For 1 project currently under preparation of the
final report, the advice is to be taken.) and suggested measures were agreed with project
proponents etc. and relevant authorities at the time of the project appraisal. In general, advice
was followed in reviewed projects, however, it was found difficult to take some advice which
is described later. In addition, it was confirmed that the advice on the project implementation
was properly followed. At the end of the chapter, a separate table summarizing the response to
the advice on the project implementation is attached in Table 2 24.
・ In some cases, the follow-up of the advice was challenging. This is partially because
environmental and social consideration documents such as EIA had already been approved or
had been being subject to the official review process when the Advisory Committee meeting
was held at JICA’s environmental review stage. In such a case, measures following the advice
was agreed at the time of the project appraisal on top of EIA. Such challenges are confirmed
in 3 projects (Nos.24, 28, 29).
・ Details of 3 projects are shown as follows:
o In the case of No.24 North-South Expressway Construction Project (Ben Luc - Long
Thanh Section) in Viet Nam, EIA report was prepared with the assistance of ADB and was
approved by Ministry of Natural Resources and Environment(MONRE) on 14 September
2010. However, since the Advisory Committee meetings were held on 16 February 2011
and on 4 March 2011, the advice could not be reflected into the EIA.
o In the case of No.28 Batchenga - Lena Road Project in Cameroon, the EIA report was
concluded in July 2012, and the Advisory Committee meetings were held on 10 November
2014 as the WG and on 1 December 2014 as the general meeting for finalizing advices.
Therefore, the advices could not be reflected in the EIA.
o In the case of Project No.29 Rengali Irrigation Project(Phase 2)in India, the Advisory
Committee requested on 6 October 2014 to revise a sentence of “No population will be
displaced due to this canal project” as involuntary resettlement occurs for 138 informal
households based on the latest RAP”. However, this comment could not be incorporated
into the EIA since the State Government had already begun the review and approval
procedure for the updated EIA dated March 2014.
・ For the above three projects, already approved EIAs could not be revised, but JICA and project
proponents etc. agreed on suggested measures given by Advisory Committee on top of EIA.

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2.2.3 Review of "III. Procedures of Environmental and Social Considerations"

Overview
The outline of the review is shown below. Ten Category C projects are excluded from this section
as the procedures in accordance with JICA GL are not relevant to Category C projects after
categorization.

・ Out of the 90 projects, alternatives analysis was conducted 79 projects in total, namely in 41
Category A projects and in 38 Category B projects excluding 4 projects (Nos.62,65,66,76)
which are to be constructed in the premises of the existing facilities (details are provided in the
next section (2)).
・ Seven projects were classified into Category FI (Nos.43,56,57,58,59,60,81). For those projects,
the institutional capacity on environmental and social considerations of financial
intermediaries 1was examined. Moreover, out of 7 projects, 6 projects do not expect to have
Category A subproject at the time of the environmental review (Nos.43,56,57,59,60,81). On
the other hand, in the case of Project No.58, it was agreed that the environmental review process
and information disclosure for Category A project needs to be taken if any subproject is
categorized as Category A prior to its implementation.
・ The preparatory study in assistance with JICA was conducted in 67 projects. Within all 67
projects, the environmental and social considerations steps required were taken including
scoping, EIA study, information disclosure, and stakeholder meeting. As for other 33 projects,
the preparatory study was not conducted.
・ Preparation of Environmental Checklist were confirmed with 39 projects out of 42 Category B
projects. For the projects which did not make use of the Environmental Checklist, the
equivalent information was checked with EIA and other documents. For Category A projects,
the necessary information was collected and checked with EIA and/or RAP.
・ As for the timing of E/S loan environmental appraisal/review under the current GL, there are
two options; prior to the provision of E/S loan or at the provision of loan to the targeted project.
Four E/S loan projects (Nos.13,23,34,55) have skipped the environmental review as per the
JICA GL as the environmental and social impacts were to be examined through the E/S as a
loan components. Environmental and Social impact assessment survey components include
support for preparation/review of EIA and/or RAP if already developed and support for
environmental/social monitoring activities. For Project No.13, environmental and social
monitoring would be supported. Project No.23 included a support for review of the draft EIA
report and conducting supplemental surveys in accordance with JICA GL (no land acquisition
for the project). Project No.34 has a support for preparation of EIA and RAP reports (the land
acquisition process has not yet started and construction work has not been started accordingly).
For Project No.55, a support for preparation of the EIA report was included.

1
Financial Intermediaries(FI): FIs include public and private financial services providers, including national and regional
development banks, which channel financial resources assisted by JICA through two-step loan to a range of economic
activities across industry sectors. (Defined with reference to WB ESF ESS9, p.91)

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・ "Submission of Monitoring Results and Disclosure "


⇒ It will be described in detail in Section 2.2.3 (3) .
・ There is one project (No. 31) where the third party requested the project proponent for
disclosure of monitoring results, and asked the monitoring process and results which were
properly responded.
・ “Discrepancy between Environmental Review Results and Monitoring Results”
⇒ It will be explained in detail in Section 2.2.3(6).
・ There was no reviewed project in which JICA asked project proponents etc. to take appropriate
actions in accordance with the signed agreement and disbursement was suspended due to a lack
of appropriate response by project proponents etc. with respect to environmental and social
considerations.
・ There are two projects in which a significant change of the project scope occurred. In Project
No.4, the project area was expanded due to development of Phase 2 area, namely “Zone B”,
and the project has undergone the “significant change” process. For Project No.9, the design
of the access road component was changed and regarded as a “significant change”.
・ There is no reviewed project for which JICA recommended MOFA to suspend the cooperation
project due to environmental and social considerations.
・ There are 8 projects (Nos.39, 40, 44, 45, 83, 84, 85, 89) under “3.4 Technical Cooperation for
Development Planning”. Stakeholder meetings on SEA were carried out in 7 projects
(Nos.39,40,44,45,83,84,85) except for Category C project (No.89).
⇒ Regarding the technical cooperation for development planning, it will be explained in detail
in Section 2.2.3(8).

Alternatives Analysis and Without Project Scenario


・ Out of the 100 projects for review, the alternative project plan were examined for all 41 projects
Category A projects. In addition, the alternative analysis has been conducted with 38 Category
B projects except for the ones which are implemented within the premises of existing facilities
(Nos.62, 65, 66, 76). In total, the alternatives have been examined in 79 projects.
・ In Category A projects, most projects examined without-project scenario. As an exception, in
the case of co-financing projects for which EIA was prepared with the support of another donor
such as ADB and AfDB, without-project scenario was not examined in the respective report.
・ Methodological pattern observed with 70 projects out of the 79 projects were summarized
below. Remaining 9 projects are excluded from this analysis as alternative analysis was
conducted in a simple methodology for (1) the SME support projects are proposed by the
private sector (verification survey/feasibility survey with the private sector for disseminating
Japanese technologies, promoting private sector cooperation and BOP business collaboration
project); and (2) technical cooperation projects accompanied with small scale construction
work but limited environmental and social impacts.
・ The examination of alternative project sites/routes are most common in 51 projects.
Subsequently, project design alternatives were considered in 34 projects; alternatives of the

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construction and operation method were considered in 9 projects (especially, the construction
method was examined in 4 projects); the alternative implementation schedules were considered
in 4 projects (including selection of priority projects in the M/P). As for 7 technical cooperation
projects for development planning which conducted SEA, it was confirmed that alternative
project sites and project designs were considered in 4 projects each; and both alternative
construction and operation methods and implementation schedules were examined in one
project each.
・ For 31 Category A projects out of 70 projects which conducted alternative considerations,
whether alternatives were considered from economic, social and environmental aspects was
reviewed. Alternative analysis from both economic aspects (e.g. project cost, feasibility, etc.)
and environmental and social aspects are examined for 24 projects. More specifically, the
alternative analysis on the economics aspect was confirmed in 27 projects, environmental
aspects in 28 projects, and social aspect in 28 projects. The alternative analysis on social aspects,
especially land acquisition and resettlement aspects, were often confirmed.
・ Technical alternatives were analyzed for 25 projects. In addition, it was found that alternative
analysis includes some other aspects such as geography, effectiveness, demands, safety,
difficulty to obtain permissions, the construction period, a flood risk, and consistency with
higher level governmental policies.
・ Quantitative alternative analysis was confirmed in 22 projects. It was often observed that the
quantitative analysis was partially conducted because it is not easy to evaluate alternatives
quantitatively for all the options. More specifically, alternative considerations were often
conducted at several sites or routes and at the different planning stages under one project. The
limited availability of existing data for the alternative consideration at the early planning stage
is also another challenge for quantitative evaluation. In addition, there are 2 projects (Nos.32,
34) with which alternative analysis were evaluated quantitatively by Multicriteria Analysis
(MCA) using weighted evaluation parameters and both the quantitative and qualitative data.
・ Alternative analysis was conducted by considering quantitative and qualitative positive effects
in 17 projects. For example, the regional economic effect (including increase in employment),
improvement of traffic congestion, easiness for extension, connectivity with other
transportation, improvement of transportation network, safety, the economic internal rate of
return (EIRR), less travel time, GHG emission reduction, appropriate treatment of heavy metals,
reduction of odour, improvement of water quality, improvement of air quality and noise due to
improved traffic congestion, environmental conservation by improvement construction (e.g.
river bank and sand beach), indirect impact of improved agriculture production by the power
generation projects, potential future development, urban planning potentials were considered
as positive effects. Although these positive effects were considered, these positive effects are
both for the alternatives selected and not selected.
・ Most without-project scenario was analyzed qualitatively. Examples of qualitative and
quantitative evaluation are shown in the following tables, respectively.

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Table 2-3 Example of Qualitative Without-Project Scenario


Project
Project Name Example of Without-project Case including Qualitative Evaluation
No.
1 Navoi Thermal Power In the case where the project is not implemented, existing old power plants
Station Modernization (Units 3 and 8) need to be operated continuously and the air quality around
Project (Uzbekistan) the power plants will remain in adverse conditions. In addition, the reliability
of the facilities will also decrease so that it increases the possibility of an
accident.
3 Turakurgan Thermal Power In the case where the project is not implemented, existing old and inefficient
Station Construction thermal power plant need to be operated continuously and cannot respond to
Project (Uzbekistan) the increasing power demand.
7 The Kanchpur, Meghna, In the case where the project is not implemented, a serious traffic problem
and Gumti 2nd Bridges will not be resolved, and accordingly the traffic accidents and environmental
Construction and Existing pollution will not be mitigated.
Bridges Rehabilitation
Project (Bangladesh)
Source: Prepared by JICA Study Team

Table 2-4 Example of Quantitative Without-Project Scenario


Project
Project Title Example of Without-project Case including Quantitative Evaluation
No.
27 Flood Risk Management In the case where the project is not implemented, while it can cope with the
Project for Cagayan de Oro flood with 2 to 5-year probability scale, but not with 25-year probability
River (Philippines) scale, which is the project target.
Source: Prepared by JICA Study Team

・ Below are examples of other specific alternatives.

Table 2-5 Examples of Alternatives


Project
Sector Project Name Example of Alternatives
No.
3 Thermal Turakurgan ・Power Station: The plan without project implementation, and
Power Thermal Power Station alternatives on site selection, fuel, and power generation system
Station Construction Project were examined in EIA or in Preparatory Study.
(Uzbekistan) ・Transmission Line: The plan without project implementation, and
an alternative plan of expressway to install the transmission line as
site selection were examined in EIA.
14 Road Mandimba-Lichinga Road Since the project improves the existing roads, without-project case,
Upgrading Project a plan with consideration of the range of construction influence,
(Mozambique) and a plan to alter the whole road reserve were examined as
alternatives with consideration of the road alignment and ROW
width.
53 Urban Transportation Line- Route of the Metro Line 3 was selected from 2 candidate routes,
3 Development Project and transport system was selected in two steps. In the first step, all
(1)(Panama) the possible urban transport system were listed and evaluated by 4
evaluation criteria which are agreed by Metro Agency and JICA
Study Team. In the second step, selected 6 transportation system
were examined, and 10 comparison items were selected, and
analysis was carried out from the viewpoints of technical validity,
cost, schedule, demand, land acquisition/resettlement, and
environmental impacts. After a series of discussions and analysis, it
was concluded to adopt Pan American Route, and the straddled‐
type monorail was adopted as the most suitable system for the Line
3.
79 Water The Project for Without-project case and three alternatives were compared from
Supply Augmentation of Water viewpoints of difficulty of construction (presence of bedrock), the

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Project
Sector Project Name Example of Alternatives
No.
System Supply System in Narok construction site area of a water purification plant, environmental
(Kenya) conditions, and maintenance costs. Finally, the alternative 3 was
selected.
(1) Alternative 1 (a plan in the F/S Report)
Alternative 1 is to first install the intake facility about 5 km
upstream from the existing central water purification plant, then
install a 200 mm diameter water pipe along the river and guide raw
water to the existing central water purification plant with natural
flow.
(2) Alternative 2
Alternative 2 plans to construct a new intake facility and a water
purification plant on the future expansion site which is next to the
current water supply facility. However, it is planned the
distribution reservoir is to be constructed upstream of this plant
considering the natural flow.
(3) Alternative 3 (Selected Plan)
Alternative 3 is to install an intake facility approximately 5 km
upstream from the existing central water purification plant as
planned in the F/S report, but the new northern water purification
plant and the distribution reservoir are planned to be installed
upstream of the river. It is planned to distribute water to the city by
natural flow only.
Source: Prepared by JICA Study Team

Submission of Environmental and Social Monitoring Report


・ The environmental monitoring results were periodically submitted for 51 projects among 77
reviewed projects with exception of the Category C, Category FI, and Technical Cooperation
for Development Planning. Out of 77 projects, 25 projects are not in the stage of monitoring
since the construction has not been commenced, and 1 project was suspended due to a security
reason in the project site.
・ For social monitoring, 45 projects involve land acquisition and/or resettlement. Among 45
projects, social monitoring results were submitted in 29 projects. For remaining projects, land
acquisition/resettlement has not yet started in 15 projects, and 1 project was suspended due to
a security reason in the project site.

Environmental and Social Considerations by the Project Proponent in the E/S


Environmental and social impacts were to be examined in four E/S loan projects (Nos.13, 23, 34,
55) among the 100 reviewed projects, through support for drafting environmental and social
documents and for monitoring implementation provided in E/S components. In addition, in case of
Project No.13, land acquisition was carried out and the construction of the access road had been
started during the period that the components covered by E/S loan was undertaken. It was confirmed
that compensation for land was paid according to the national law prior to land acquisition, partially
some bank accounts for compensation were frozen due to overpayment of the compensation,
farming is permitted to continue in areas where construction has not started yet, and livelihood
restoration supports are provided as per the Land Acquisition and Resettlement Action Plan
(LARAP) such as vocational training on welders and mushroom cultivation promotion, and

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employment as project workers.


Disclosure of Environmental and Social Monitoring results on the JICA Website
・ Among the reviewed projects, JICA and project proponents etc. agreed on disclosure of
environmental monitoring results on the JICA web site in 45 projects. Construction work has
been started and environmental impacts needed to be monitored in 29 projects, while
monitoring reports submitted to JICA were disclosed on the JICA website for all the projects
except for 1 project (No.38), which was suspended due to the deterioration of the situation in
the project proponent.
・ Among the reviewed projects, JICA and project proponents etc. agreed on disclosure of social
monitoring results on the JICA web site in 16 projects. Land acquisition and involuntary
resettlement had begun in 10 projects which are subject to monitoring, while monitoring reports
submitted to JICA were disclosed on the website of JICA except for 1 project (No.38) which
was suspended due to the deterioration of the situation in the host country.

Differences between Environmental Review Results and Monitoring Results


・ Cases that the unanticipated impacts at the timing of environmental review was identified
through monitoring were reviewed considering whether there was a difference between the
appraisal (environmental review) and the monitoring result. Among the reviewed projects,
differences were observed in 5 projects (Nos.5, 6, 11, 24, 42). These differences were not
caused from descriptions of the JICA GL itself nor differences in understanding, instead, for
example, the happening of events that were not anticipated in the EIA stage, or issues of the
institutional capacity of project proponents etc. and related agencies in host countries. In all the
projects, it was confirmed that project proponents recognized and addressed the issues with
these projects.

Projects that Significant Changes Happened


・ Among 100 reviewed projects, significant changes as defined in the JICA GL were confirmed
in 2 projects. For the No.4 Thilawa Special Economic Zone (Class-A Area) Development
Project, the Zone B (Phase 2) development which was added to the plan but implemented later,
was recognized as a “significant change” due to the expansion of the investment area. For the
project No.9 Matarbari Ultra Super Critical Coal-Fired Power Project(1), the design change of
the access road component was regarded as “significant change”.

Environmental and Social Considerations for Technical Cooperation Projects for Development
Planning
Among 100 reviewed projects, 8 technical cooperation projects for development planning were
included. One project which is Category C is excluded from the scope of review of this section. For
the rest of 7 projects, necessary process undertaken in line with the JICA GL are reviewed as follows.

・ Screening was conducted in all 7 projects.


・ Scoping including preliminary-scoping or draft scoping was conducted in all 7 projects.
・ Meetings between JICA and project proponents etc. were confirmed in all 7 projects.
・ Disclosure of agreement documents and reports were confirmed in all 7 projects.

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・ Implementation of alternative analysis and Stakeholder Meetings (SHMs) at the SEA stage
were confirmed in all 7 projects. More specifically, alternative analysis including examination
without-project scenario was conducted in all projects, and alternative location of the project
site/route, alternative plan of development scenario/strategies were examined. SHMs were
conducted at the M/P preparation stage to share basic understanding regarding development
planning with local people and for explanation/meetings on draft M/P. It was confirmed that
SHMs were conducted at several stages, not only one stage, in accordance with progress of
M/P, though the number of attendances was different by projects (total 101-492 participants).
・ As for the unexpected environmental and social impact after completion of technical
cooperation projects for development planning, in case of No.44 Joint Feasibility Study for
Mumbai-Ahmedabad High Speed Railway Corridor in India, it was confirmed that some
complaint letters are from farmers (including organization) whose lands were affected were
reached, the JICA office conveyed contents of appeals to the project proponent and requested
them to correspond to issues after conducting interviews accordingly.

2.2.4 Appendix 1 – 6 Environmental and Social Considerations Required for the Project Proponents

Overall Trend
The review results on environmental and social considerations required for project proponents etc.
as per Appendix 1-6 of JICA GL are summarized as follows. Since the Category C projects (10
projects: Nos.25, 61, 63, 82, 89, 90, 91, 97, and 100) are not subject to the environmental review,
those projects were excluded from analysis, and remaining 90 projects are reviewed.

It was confirmed that preliminary survey and examination were conducted for all the 90 projects on
environmental and social impacts in the planning stage. For the status of alternatives and mitigation
measures to avoid and minimize the impacts, among the surveyed 90 projects, alternatives were
examined for all the 41 Category A projects and all the 42 Category B projects, excluding 7 Category
FI projects.

・ Qualitative and qualitative evaluation of the costs and benefits of environmental and social
considerations was observed in 69 projects, and 21 projects which are SME support projects,
technical cooperation projects, or Category F1 projects, are excluded.
・ Whether environmental and social considerations related costs and benefits are harmonized
with economic, financial, institutional, social and technical analysis of the project was studied.
As a result, 44 projects calculated EIRR including environmental, social costs and benefits. For
example, in the case of Project No.29 India: Rengali Irrigation Project (Phase 2), the
implementation cost of environmental management plan is included in the project costs, and
Project No.35 Kenya: Olkaria V Geothermal Power Development Project includes
environmental management costs, land acquisition costs, etc. in the project cost. In each case,
EIRR is calculated.
EIRR calculation is not applicable for another 46 projects; including Grant Projects (19 projects
excluding category C), 7 FI projects, 7 projects for Technical Cooperation for Development

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Planning, 3 Technical Cooperation projects, 3 E/S projects, and 6 SME support projects.
・ Among total 83 Category A and B projects, 76 projects carried out EIA/IEE or conducted the
IEE level of investigation (including SEA of M/P study). As for the 7 projects in Category B
(Poverty Reduction Grant Project and SME Support Project: Nos.68, 92, 93, 94, 95, 98, and
99), which did not carry out EIA study due to no requirements in the host country, information
was collected through project appraisal. As for whether the results of the environmental and
social considerations, including alternatives and mitigation measures, are recorded as separate
documents or as part of other documents, it was fulfilled for all the projects. In particular, in
the case of projects with any significant impact, it was confirmed that all the Category A
projects have prepared the EIA reports.
・ Regarding preparation of the EMP and Environmental Monitoring Plan (EMoP), it was often
found that the EMP needed to be updated at the detailed design stage, and the cost of EMP and
EMoP was included in the project proponent's administrative/management cost or the
contractor's contract amount. As for the survey item of "Scope of Impacts to be Assessed",
scoping was conducted in 82 projects. (Not applicable to 7 FI projects. For Project No.85, it
will be implemented in the D/D Study.)
・ Calculation and evaluation of GHG emissions were conducted quantitatively in the JICA study
reports (e.g. F/S report) or EIA for 20 out of 90 projects (Nos.3,6,7,8,9,10,13,14,18,20,21,
35,38,41,51,53,67,70,79, and 95). One project did not conduct any JICA study (No. 22) and so
the calculation and evaluation results of GHG emissions were reported in the advisory
committee meeting. GHG emissions are mainly calculated in the sectors of power generation,
railways, roads, and airports.
・ Common method to announce the SHM or invite to SHM are announcement through
community representatives, sending invitation letters, posting an advertisement on the
newspaper. In addition, announcement via the notice board, telephone calls and radio were also
used. In a rare case, announcement on the website, by individual visits, and with use of a loud-
speaker are also found in some projects.
・ As for the timing of announcement for stakeholder meetings, in many cases, there were no such
written records because the preferred announcement timing is not specifically described in
JICA GL. However, the advance notice was commonly done one week or 10-15 days before
SHM. In some projects, the meeting announcement was done 2-5 days before the SHM or 3
weeks before.
・ The languages used in the stakeholder meetings were mostly local languages, though there
were no written records in some projects. In case the host country had official language, both
the local language and official language were used. For instance, the official languages used in
the stakeholder meetings include English (in India, Sri Lanka, the Philippines, Cameroon, and
South Sudan), French (in Arabic zone, Cameroon, and South Sudan), Russian (in Uzbekistan),
Spanish (in Central and South America) and Portuguese (in Mozambique). A variety of local
official languages were used in India and the Philippines. For rare cases, Maa language was
used for the meeting with Masai tribes in Tanzania, and a local language, other than Portuguese,

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was also used in the stakeholder meeting in Mozambique.


・ As for the method of consultation, public meetings with local residents were commonly used,
and in some projects, Focus Group Discussions (FGDs) and interviews were also conducted.
As a rare case, consultations by visiting individual households were conducted.
・ The commonly discussed contents were summarized by projects as follows:
Loan/Grant Projects (including PSIF): Discussed contents varied according to the project
stage; however, for the EIA/IEE, the project summary, expected environmental and social
impacts, findings of the surveys, environmental mitigation measures, and future schedule were
generally discussed. For the RAP/ARAP, the project summary, compensation and assistance
policy, future schedule, and GRM were commonly discussed. In some projects, more specific
issues such as the size of a new house in a resettlement site, the project-related employment
opportunities, safety issues for the road project, details of workers’ camps, the traffic
management plan during the construction period, were discussed in stakeholder meetings.
In addition, stakeholder meetings were sometimes held with local residents for
RAP/Abbreviated RAP (ARAP) and EIA/IEE at the same time in several projects. There were
some projects for which additional FGDs were held with local residents, and such FGDs were
also held for the socially vulnerable groups including slum residents, female residents, the poor,
the Scheduled Castes and Scheduled Tribes in some projects.
Technical Cooperation (Development Planning): Meetings were organized at the SEA stage,
and the project outline, planning, expected environmental and social impacts were discussed,
and question and answer session was held.
SME Support Projects: Though there was no official requirement of conducting stakeholder
meetings with local residents for SME Support projects, in one project, the stakeholder meeting
was conducted by project proponents etc. (a Japanese company). In the meeting, the project
proponent etc. explained the technology of their compost plant to local residents and concerned
people, and issues concerned waste, a request for local residents to join the environmental
monitoring committee and others were discussed.
FI: FIs shall confirm stakeholder meetings of sub-projects. In this regard, it was confirmed that
a sub-project (solar power generation) under Project No. 43 organized consultation meetings
with representatives of local communities and concerned people for the EIA (no RAP was
prepared because of no land acquisition nor resettlement). The contents of the meetings include
the project outline, time schedule and Q&A. More specifically, the consumption amount of
water, the amount of cutting trees and a request for installing the solar power panel at near
education facility were discussed.
Technical Cooperation /Category C: Conducting SHM is not applicable.
・ The number of participants for each meeting was analyzed for Category A projects. It was
found that the number of participants in each meeting significantly varied depending on the
project. The number of Project Affected Persons as well as their geographical distributions
varied depending on the project (e.g. the linear project and the non-linear project, and the new
construction project and the expansion or improvement project of the existing facility),

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therefore, it is difficult to set a preferable guideline value of the appropriate number of


participants per discussion. For instance, although participation of more than 500 people was
also found in one project (No.27), in order to ensure the meaningful participation, several
supplementary measures were adopted such as distributing the handouts and increasing the
number of the organizer’s staff. There were also two projects (Nos.17 and 32) in which
additional consultations were conducted to encourage more Project Affected Household (PAH)
participation and to improve PAH’s understanding.
・ Mitigation measures for risks of stakeholder engagement such as consensus building among
various stakeholders with different interests and the socially vulnerable groups are studied.
More specifically, whether the consultation meeting or FGD was organized for specific groups
was studied. For example, in Project No.2, interviews were conducted through individual visits,
and FGDs were conducted among people making incense sticks at home, people bathing in the
river, three-wheeled taxi drivers and school children. For Project No.32, a separate discussion
was held with affected communities with many informal occupants.
・ 60 projects have plans or measures for the socially vulnerable groups, and remaining 30
projects are not subject to significant impacts on the socially vulnerable groups since these are
Technical Cooperation for Development Plannings or projects which are implemented in the
existing facilities. The examples of consideration for socially vulnerable groups include
financial compensation, vocational training, provision of employment opportunities, and
additional considerations for residences in the resettlement site. Additionally, prioritized
employment for women and the youth, opening bank accounts to women so that women can
receive compensation, and prioritizing physically handicapped persons to allocate the first floor
of the resettlement residence.
・ Good practices of stakeholder analysis, responses from project proponents etc. to the third
party’s request, and consideration for the socially vulnerable groups are described in detail in
2.2.4(9), 2.2.4(10), 2.2.4(11).
・ The definition of WB, ADB, and IFC regarding “Critical Natural Habitats” and “Significant
Conversion and Significant Degradation” are summarized in “Chapter 4 Draft Discussion
Points for Revision of JICA GL for Environmental and Social Considerations” of this report.
The illegal logging has not been confirmed in all the reviewed projects.
・ Regarding the status of “involuntary resettlement”, among the 90 projects, RAP/ARAP was
prepared in 39 out of 44 projects with land acquisition. 5 projects for which RAP/ARAP were
not prepared, the compensation policy and implementation status/records of the stakeholder
meetings were confirmed with the environmental check list and agreed with the project
proponents etc.
・ Consultation meetings regarding resettlement plans were conducted in all the 39 projects for
which RAP/ARAP were prepared.
・ Regarding avoiding and minimizing involuntary resettlement and the loss of livelihood, it was
found that a total of 44 projects considered measures to avoid and minimize the impact.
・ Among 37 projects involving physical resettlement, 28 projects agreed on implementation of

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livelihood restoration assistance and prepared the livelihood restoration plan. Although 8
projects have physical resettlement, they have not prepared the livelihood restoration plan
because resettlement was either set-back or shifting to the vicinity place and livelihood
restoration was not anticipated, or because it was confirmed that none of residents would lose
livelihood in the survey.
・ With respect to PAHs’ livelihood, whether PAHs restored their livelihood, income
opportunities and production level was surveyed for 5 projects which planned the livelihood
restoration program out of 8 projects which field survey was conducted. Since surveyed
projects are in the implementation/preparation stage for livelihood restoration, it is too early
to conclude whether livelihood was restored or not in this study. The current survey results are
shown as follows.
o Project No.5 Delhi Mass Rapid Transport System Project Phase 3 (India):
JICA Study Team visited the relocation site in the field survey and interviewed some PAHs.
At the relocation site, social infrastructure such as a medical facility and water supply
facilities were in place, and it was confirmed that they were generally satisfied with the
living environment. In addition, no complaint was received from the interviewed residents
for the livelihood restoration assistance. In addition, external monitoring has been
conducted for the relocation site for which physical resettlement has already been
completed, and no particular complaint was reported regarding the relocation site and its
living environment.
o Project No.13 Indramayu Coal Fired Power Plant Project (E/S) (Indonesia):
From October 2016 to August 2018, 300 people participated in the agricultural skills-
based livelihood restoration programs and the non-agricultural skills-based programs, and
the programs have been continuously provided. Additionally, PAHs were allowed to
continue farming on the project sites except for access roads and substation sites.
o Project No.24 North-South Expressway Construction Project (Ben Luc - Long Thanh
Section) (Viet Nam):
JICA Study Team visited PAHs’ new housing and conducted interview. An interviewed
PAH mentioned that their revenue increased after relocation and their life became easier
because they are now closer to schools and hospitals. In addition, though the livelihood
restoration program was announced many times, they did not join the program because
they were not interested. Another PAH also mentioned that their living expense increased
due to their lifestyle change from nearly self-sufficient to buying food from the market
although they did not have to change their job due to resettlement. To cope with this
difficulty, the local government provides support for the secondary job.
o Project No.36 Infrastructure Development Project in Thilawa Area Phase I (Myanmar):
- Port Subproject: According to the project proponent, the social monitoring on
compensation payment has been already carried out. With respect to the livelihood
restoration monitoring, it is not yet completed since follow-ups become difficult due to
PAHs’ moving. Although their original address was stated in the compensation agreement

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PAHs, PAHs moved out after compensation payment. However, follow-ups for PAHs’
livelihood restoration is being attempted by the project proponent as per JICA’s request.
- Power Subproject (transmission line and substation): Social monitoring of the crop
compensation payment to PAHs for farmland affected by transmission towers was carried
out, and it was confirmed that compensation was paid without any issue and the agreement
was signed by PAHs. Livelihood restoration monitoring was not included in the
Abbreviated Land Acquisition Plan as the affected land area was limited and no significant
negative impact on their livelihood was expected.
- Power Subproject (gas pipeline): Monitoring for compensation payment has been
implemented. Regarding livelihood restoration monitoring, follow-up surveys were
difficult since the targeted three households were grazers, and no results were available.
o Project No.37 Rental Factory Development Project for SMEs (Viet Nam)
This project site is located in the existing industrial park which was already developed by
the industrial park owner. Livelihood restoration is not applicable for this project since
there is no new land acquisition and resettlement required for this project.
o Project No.41 Las Pailas II Geothermal Project (Guanacaste Geothermal Development
Sector Loan) (Costa Rica)
There was no impact on livelihoods as only one landowner is affected, and the land was
not cultivated and was an open area at the time of planning.
o Project No.42 Kenya-Tanzania Power Interconnection Project (Tanzania)
Compensation for the land and structures were already paid. Some PAHs purchased an
alternative farmland with compensation, and some purchased the agricultural equipment
like tractors since they already possessed enough farmland, or others moved out of the
village and shifted to center of Singida. There are PAHs who did not purchase alternative
farmland because they own other farmland of a sufficient size outside the Right of Way
(ROW) or can use farmland owned by relatives, etc. Therefore, it is confirmed that this is
not caused by the lack of alternative farmland or compensation amount.
o Project No. 43 Sustainable Energy Project (Latin America and Caribbean)
This solar power generation subproject in Costa Rica was carried out in the land plot
owned by the local business operator, and no land acquisition and resettlement was
required. Therefore, livelihood restoration was not applicable.
・ Among the reviewed 44 projects of Category A and B which require land acquisition, 43
projects established the GRM. The remaining 1 project (No.34) is not applicable at this stage
since currently the project is in the E/S stage. Besides the GRM for land
acquisition/resettlement, the GRM was set up for other issues such as noise during construction
stage in 11 projects which does not involve resettlement.
⇒Details will be described in Section 2.2.4(23).
・ "Preparing the Monitoring Plan" was studied for 83 projects excluding 7 FI projects (FI projects
do not require the monitoring plan of individual subprojects for the project appraisal since the
capacity of FI is evaluated for the environmental and social considerations instead). It is

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confirmed that the monitoring plan was prepared in all the 83 applicable projects including 8
technical cooperation projects for development planning in which the framework of the
monitoring plan is being prepared.
・ Regarding approval, disclosure and availability of copying EIAs, it is confirmed that all
category A projects except 5 projects fulfilled these requirements. Excluded projects consist of
one project which supports to prepare the EIA under E/S loan project (No.34) and the technical
cooperation projects for development planning (Nos.39, 40, 44, and 45). As for the languages
used for the EIAs, it was confirmed that all the EIAs were prepared in official languages or
languages widely used in the countries in which the projects were to be implemented.
・ Regarding availability of copying EIAs, due to common internet use nowadays, more than
several project proponents etc. provide a soft copy of the EIAs on the website for public
viewing and downloading. So far, it has been considered important to disclose EIAs in a hard
copy because of lower availability of internet access and its higher cost in the host countries.
However, in some host countries, internet access is becoming more affordable recently.
・ In the Category A projects (41 projects in total), it is confirmed that all the required items are
included in the EIAs as described in the JICA GL at the appraisal.
・ Regarding the EIA implementation status for projects which are Category A due to a large scale
of involuntary resettlement, EIAs were prepared in all 6 projects (Nos.2, 7, 11, 27, 28, and 38).
・ ⇒ Details will be described in Section 2.2.4(24) .
・ As for the JICA GL Appendix 3 “Illustrative List of Sensitive Sectors, Characteristics, and
Areas”, applicability of the “sensitive sectors” was confirmed.
・ ⇒ Details will be described in Section 2.2.4 (18) .
・ With respect to the JICA GL Appendix 6 “Items Requiring Monitoring”, except for 7 Category
F1 projects and 7 technical cooperation projects for development planning, in the all 76 projects,
applicability of monitoring items, description of standard values, monitoring plan during
construction and operation are largely confirmed.
⇒ Monitoring of livelihood restoration will be described in detail in Section 2.2.4(19).

Investigation and Examination of Environmental and Social Impacts in the Planning Stage
All projects except SME support projects and private partnership projects examined environmental
and social impacts of their projects in the planning stage.
Examination of Alternatives and Mitigation Measures to Avoid and Minimize Impact
Out of 90 reviewed projects, 41 Category A projects and 42 Category B projects except 7 Category
FI projects considered alternatives and studied mitigation measurements to avoid and/or minimize
the negative impacts. Study results of these alternatives are, if the EIA/IEE and preparatory survey
are being carried out, described in the Preparatory Study report.
Reflecting the Examination Results in the Project Plan
In 79 projects which conducted alternative considerations, the alternatives were considered in terms
of technical, cost, and environmental and social aspects and the alternative which has a relatively
small environmental and social impact was adopted. In general, there was a tendency to adopt the

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alternative which land acquisition and involuntary resettlement have less impact on the project.
Environmental Impact Assessment Reports prepared for the Project with Significant Impacts
It was confirmed that in the particularly large impact projects, EIA or Environmental and Social
Impact Assessment (ESIA) was prepared in all Category A projects. Among them, there was a
project which EIA was prepared to meet the requirements of JICA GL although it is not legally
necessary to prepare and approve EIA in the project proponents etc.(No. 32 North East Road
Network Connectivity Improvement Project (Phase I) and others). In the case of Category A projects,
basically an EIA study is being conducted in parallel with the Preparatory Study, but in co-financing
projects with ADB/AfDB such as No. 24 North-South Expressway Construction Project (Ben Luc
- Long Thanh Section) and No.28 Batchenga - Lena Road Project, EIA was implemented and
approved with the support of the ADB /AfDB.
The Committee of Experts formed for the Particularly High Impact Projects, or Projects that
Have Many Objections
Among the reviewed projects, the project-specific committee was not formed (excluding the
committee for land acquisition or environmental management that was formed by administrative
reason of the host country).
Utilization of the Previous Evaluation (Tiering)
According to “the Basic Matters relating to the Guidelines etc. to be Established by the Competent
Minister in Accordance with the Provisions of the Environmental Impact Assessment Act (The
Environment Agency Notification No.87 of December 12, 1997) (so called ‘the Basic Matters’)” of
Japan, it is required to describe alternatives to avoid and minimize impacts which were considered
in the previous planning stage in the EIA as tiering.

Excerpt from “the Basic Matters relating to the Guidelines to be Established by the Competent
Minister in Accordance with the Provisions of the Environmental Impact Assessment Act”:

Section 4-1(5) “[in cases where] multiple plans concerning location, etc. have been compared,
clarify how environmental impact is avoided or minimized in the course of such decision-making.”

The WB’s or IFC's practices/requirements of tiering has not been confirmed with the written
document such as SGP.
Cases that fall under “Indivisible Projects, Derivative or Secondary Impact, Cumulative
Impacts”
75 projects were analyzed except 10 projects in Category C, 7 projects in Category FI, 3 projects in
Technical Cooperation, 4 projects in SME support and one other project.

In the case of indivisible projects, 4 projects were confirmed as the project with an indivisible project.
Among these 4 projects, one is a road project in which one section is co-financed by JICA and AfDB
and other sections are financed and implemented by AfDB (No. 28).

In No.35 Olkaria V Geothermal Power Development Project, well drilling was carried out by the

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project proponent, so it is considered as indivisible projects. JICA reviews the EIA prepared by the
project proponent for the well drilling project and confirms that there is no discrepancy from JICA
GL.

Table 2-6 provides an overview of the reviewed projects that have an indivisible project.

Table 2-6 Overview of the Projects which have an Indivisible Project


Project Environmental
Project Name Associated Facility
No. Category
Rades Combined Cycle Rades III switch yard project
19 Power Plant Construction A
Project (Tunisia)
It is planned to transport the sludge currently accumulated in
the existing sludge disposal site to the existing outside
disposal site under the preparatory construction work of
Bortnychi Sewage Component 5 which is not financed by Japanese ODA of the
Treatment Plant Project.
22 A
Modernization Project It is planned to carry the soil around the disposal site
(Ukraine) together with the sludge, but whether the soil is
contaminated, and if contaminated, the extent and depth of
actual contamination are unknown at the project appraisal
stage.
In this project, the road between Bachenga - Lena (263.6 km)
are divided into 4 sections. JICA co-financed road pavement
and construction between Mankin – Yoko, the third section
(82.1 km, hereinafter "JICA Loan Section") with AfDB.
Batchenga - Lena Road
28 A JICA conducted the project appraisal on the third section
Project (Cameroon)
(between Mankin - Yoko) for cofinancing. The other
sections of this project are considered an indivisible project,
and the environmental and social considerations were
confirmed by JICA for these sections.
Olkaria V Geothermal Geothermal well drilling project with KenGen funds
35 Power Development Project A
(Kenya)
Source: Prepared by JICA Study Team

The derivative or secondary impact was identified in 2 projects among 75 reviewed projects as per
the JICA GL’s definition.

Table 2-7 Projects with Derivative or Secondary Impacts and Mitigation Measures
Implemented
Project
Project Name Derivative or Secondary Impacts Mitigation Measures
No.
21 National Road At the Advisory Committee at the Draft Regarding the impact raised by the Advisory
No.5 Final Report (DF/R) stage, it was pointed Committee, "the importance of waste
Improvement “[t]he number of shops and houses reduction/proper disposal measures and
Project (Thlea around the road is expected to increase as prevention of water pollution caused by
Ma'am- the indirect and cumulative impact of domestic drainage, etc." are described in the
Battambang and this project, so measure should be taken final report, and the issues are addressed to
Sri Sophorn- for waste reduction, proper disposal relevant organizations through the project
Poipet Sections) measures and prevention of water proponent at the time of project appraisal.
(I) (Cambodia) pollution caused by domestic drainage
etc. It is necessary to raise the issue to
relevant organizations through the

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Project
Project Name Derivative or Secondary Impacts Mitigation Measures
No.
project proponent so that necessary
measures will be taken in parallel to this
project."

41 Las Pailas II ・General provision on EIA in Costa Rica Construction of the road has completed.
Geothermal and the technical manual of EIA Water conduit line construction is completed
Project procedures mention that “Environmental about 80% (since approval of specifications by
(Guanacaste Impact Survey need to be conducted government was delayed, it is currently under
Geothermal after categorizing the project area in 3 construction).
Development areas considering the environmental As for other social programs, the following
Sector Loan) characteristics of the project location installations have been completed (based on
(Costa Rica) area. 3 areas are Area of the Project or results of the interview with the residents);
directly affected (AP), Direct Influence additional construction of classrooms in
Area (DIA) and Indirect Influence Area schools, construction of bus stops, construction
(AII)." In the Preparatory Study and EIA, of sidewalks, improvement of power system of
Curubande community, which is located a health center, installation of fences for a
12 km south west from project area, is soccer field, installation of solar lamps on a
identified by Instituto Costarricense de playground of a day care center.
Electricidad (ICE) as Las Pailas
Geothermal Power Plant Project’s
Indirect Influence Area (the area is about
3.7 km2).
・ Positive impact was observed such as
construction and maintenance of road for
the power plant facilities and social
services provided to community
residents.

Source: Prepared by JICA Study Team

Regarding the cumulative impacts, among analyzed 75 projects, there are 2 projects for which
cumulative impacts were identified based on the definition of JICA GL 1. The sector of these 2
projects was both power generation. In addition, the projects have an existing power plant, and the
project is expected to have a cumulative impact on biodiversity conservation, air, water quality,
noise, soil, waste, etc. Table 2-8 shows the details of two projects.

Table 2-8 Projects with Cumulative Impacts and Mitigation Measures Implemented
Project
Project Name Cumulative Impacts Mitigation Measures Implemented
No.
19 Rades Combined A cumulative impact of the existing power As the result of air dispersion simulation
Cycle Power Plant plant on air quality and water quality after including the influence of the existing
Construction operation power plant, it is not expected to exceed
Project (Tunisia) the host country’s and IFC standards.
As the result of the thermal effluent
dispersion analysis, it is not expected to

1
Referring to IFC’s Performance Standard 1, JICA defines the “cumulative impacts” as cumulative impacts resulting from
the incremental impact, on areas or resources used or directly impacted by the project for which JICA cooperates, from other
planned or reasonably defined developments at the time the risks and impacts identification process is conducted (e.g.
scoping) .

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Project
Project Name Cumulative Impacts Mitigation Measures Implemented
No.
have a negative impact on the rare species
of eelgrass, and mitigation measures are
not planned.
35 Olkaria V As this project is in Phase 5, the As result of simulation which include
Geothermal Power cumulative impacts of future development impacts of the existing power plants, it
Development were assessed based on the past impacts was pointed out the possibility that air
Project (Kenya) on biodiversity, air quality, water quality, pollution and noise level might exceed the
noise, soil, waste, etc. WHO standards. However, for the
residents in the possible affected area, no
measure is planned since they are
supposed to be relocated by Phase 4 work
and the monitoring is to be continued.
Source: Prepared by JICA Study Team

Cases that fall under "Protected Areas that are Specifically Designated by Laws or Ordinances
for the Conservation of Nature or Cultural Heritage" and their Circumference
Among 90 reviewed projects, no project was implemented in “protected areas that are specifically
designated by laws or ordinances for the conservation of nature or cultural heritage”. 7 projects have
these protected areas in their vicinities. Table 2-9 describes impacts and mitigation measures of
these 7 projects.

No. 5 Delhi Mass Rapid Transport System Project Phase 3 in India was partially operational at the
time of the field survey under this study and took measures to avoid bird strikes such as ringing a
horn when the train passes through the nearby bird sanctuary. The project site of No. 24 North-South
Expressway Construction Project (Ben Luc - Long Thanh Section) is located approximately 12 km
north of the Kanzo Mangrove Protected Forest, which is a biosphere reserve, and although this
project passes through the transition zone, the implementation of project in the transition zone is
permitted under the national law. This project implements afforestation of the mangrove, reforested
mangrove is scheduled to be monitored on a regular basis (once a year) up to three years after
reforestation. No.35 Olkaria V Geothermal Power Development Project has already started its
construction and monitoring of accidents involving animals and monitoring of landscapes are being
carried out. As for the other 2 projects, the construction has not yet started; however, conservation
plan and monitoring plan are prepared.

Table 2-9 Details of the Project Located in the Vicinity of the Area Designated as "Protected Areas
that are Specifically Designated by Laws or Ordinances for the Conservation of Nature or Cultural
Heritage"
Project The reason of project falls in the "protected areas that are specifically designated by laws or
Project Name
No. ordinances for the conservation of nature or cultural heritage " and their vicinities
5 Delhi Mass • Areas designated as protected areas or natural forests are not included in the project site.
Rapid Because the project passes near the bird sanctuary, mitigation measures such as toot horns
Transport around the vicinity is taken to avoid bird strikes.
System Project
Phase 3 (India)

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Project The reason of project falls in the "protected areas that are specifically designated by laws or
Project Name
No. ordinances for the conservation of nature or cultural heritage " and their vicinities
18 National Road ・ There is the Tonle Sap Biosphere Reserve (TSBR) on the north side of the project area,
No.5 and National Road No. 5 is adjacent to Zone 1 (transition zone) where construction of
Improvement infrastructure is allowed. The project area is far from the core area of TSBR and no work
Project (Prek permission is required.
Kdam - Thlea ・ Cultural heritage: There are no cultural heritage.
Ma am Section)
(I) (Cambodia)
21 National Road ・There is the Tonle Sap Biosphere Reserve (TSBR) on the north side of the project area,
No.5 and National Road No. 5 is adjacent to Zone 1 (transition zone) where construction of
Improvement infrastructure is allowed. Tonle Sap Lake is the largest freshwater lake in Southeast Asia,
Project (Thlea and the surrounding immersion forests are important for wildlife conservation and
Ma'am- researches in worldwide. The ROW of National Road No. 5 is already progressively used as
Battambang agricultural land and settlements, and this project would not pass through the protected
and Sri areas. During the consultations between MOE and JICA study team, it was confirmed that
Sophorn-Poipet ROW of National Road No. 5 does not pass through the TSBR. Pursat Bypass passed
Sections) (I) through Zone 1 of TSBR, but development was not prohibited. An official document was
(Cambodia) issued by the Ministry of Water Resources and Meteorology (MOWRAM) to proceed with
the project with consideration of the impact on existing irrigation facilities and water
quality. There is no need to obtain additional permits other than ESIA for this project
24 North-South This project is located about 12 km north from Can Gio Mangrove Protection Forests that
Expressway are recognized as the Biosphere Reserve (core areas) by the United Nations Educational,
Construction Scientific and Cultural Organization (UNESCO). Though the project passes through around
Project (Ben this protected forest, urbanization is permitted in the Transition zone, and the project
Luc - Long implementation has been approved by the District People's Committee and the Protected
Thanh Section) Forest Management Committee. In addition, rare species do not exist in and around the
(Viet Nam) project site.
35 Olkaria V ・ The planned project site is close to Hell’s Gate National Park. By regulating vehicle
Geothermal speed and adopting appropriate design of pipelines, the project reduces the impact on
Power wildlife habitat. Though the pipelines will be installed on a part of the road in the national
Development park, no new modification in the national park is expected due to the memorandum with
Project (Kenya) Kenya Wildlife Service (KWS). The geothermal resource development license in Hell's
Gate National Park was received, and it was confirmed that there is no problem with
Olkaria V Geothermal Power Plant Project.
・ Because Mount Longonot National Park is located in the vicinity, KWS prepares the
Ecosystem Management Plan of Hell’s Gate National Park, and KenGen needs to follow
this plan and carry out geothermal development accordingly. In addition, a memorandum of
understanding on geothermal development has been signed for Hell’s Gate National Park
and Mount Longonot National Park.
41 Las Pailas II ・ The project site and another site for additional facilities are adjacent to Rincon de la
Geothermal Vieja National Park. The park is a part of the UNESCO World Heritage site of Guanacaste
Project Reserve (Área de Conservación Guanacaste: ACG).
(Guanacaste ・ Though the project site is not a designated area for cultural protection, petroglyphs (a
Geothermal type of stone maps) created around 800 AD was discovered during construction at the
Development power plant site of Las Pailas II. The found stones have been transferred to the National
Sector Loan) Museum as a cultural asset after the survey for buried materials, and one stone is displayed
(Costa Rica) on the power plant site to alert the concerned parties such as the contractor in the future
construction.
42 Kenya- The project area passes through Wildlife Management Area and Game Controlled Area,
Tanzania Power which are located around the National Park and Important Birds Areas. Although there is no
Interconnection special license other than EIA approval is required under the national law for project
Project implementation in these areas, SHMs were held and a consent was made before the project
(Tanzania) implementation between the Ministry of Natural Resources and Tourism and the villages
that are the authority of the area.
Source: Prepared by JICA Study Team

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Examples of “Critical Natural Habitats"


Among the reviewed projects, 5 projects are located in critical natural habitat 1. The review results
are compiled in the table below. For 2 projects (Nos. 33 and 44), conditions to implement the project
in the critical natural habitat were checked as specified in the FAQ of JICA GL. Remaining three
projects (Nos. 12,16, and 20) are not subject to these conditions since the environmental reviews
were conducted for the projects before these conditions were specified by JICA. In any case, there
is no significant conversion or deterioration, and mitigation measures such as conservation planning
and monitoring are planned.

Among these 5 projects, 2 projects (Nos.12 and 16) started construction works, and environmental
monitoring are carried out and the results are disclosed to the public. In the case of No.12 New
Bohol Airport Construction and Sustainable Environment Protection Project in the Philippines, the
biodiversity conservation plan was developed, and more than 100,000 seedlings have been prepared
since June 2018 and planting has been implemented in the project area (17 cities and municipalities).
In the case of No.16 Port Vila Lapetasi International Wharf Development Project in Vanuatu,
attempts have been made to offset while continuously monitoring the impact on coral reefs.
Environmental monitoring has not yet been conducted in the remaining 3 projects but planning of
conservation measures and preparation of monitoring plans are underway.

Table 2-10 Grounds and Verification Results that are Considered to be Critical Natural
Habitats
Project Project Name and
Grounds and Verification Results of Applied Projects in Critical Natural Habitats
No. Country
12 New Bohol Airport Although there are no national parks and protected areas in and around the project area,
Construction and according to the biodiversity survey report, natural vegetation remains in the project
Sustainable implementation area, and two valuable species according to the Philippine laws and
Environment regulations are growing in the area. In addition, it is expected that coconuts and fruit trees
Protection Project protected by Philippine laws and regulations might exist in the project area.
(Under [Reference]
Construction) Vitex parviflora (Family: Lamiaceae, Genus: Vitex)
(Philippines) IUCN Status VU
Diospyros pilosathera (Genus: Diospiros)
IUCN Status None
16 Port Vila Lapetasi 127 colonies of massive coral and around 20 m2 of branched corals were confirmed at the
International Wharf planned site to be reclaimed. However, alternative plans were compared, appropriate
Development mitigation measures were prepared, and the project was justified. Monitoring is under

1
According to the JICA GL FAQ, with reference to the definitions of the WB SGP and the IFC’s Performance Standard,
examples of critical natural habitats are as follows. In addition, it is also recognized that critical forests refer to forest areas
that are specified as critical natural habitats.
Critical natural habitats are;
1. Areas considered to be highly suitable for biodiversity conservation as well as areas critical for rare, threatened, migratory
and endangered species, including the following:
(1) Habitats that are of particular importance to species that fall under "Critically Endangered (CR)" and "Endangered (EN)"
in the Red List of the International Union for Conservation of Nature (IUCN), (2) Habitats that are of importance to the
endemic and / or limitedly distributed species, (3) internationally important habitats that support migratory species and/or
flock-forming species, (4) critically endangered ecosystems and/or unique ecosystems, (5) areas related to important
evolutionary processes
2. Similar examples other than areas set forth in No.1 above include areas that local communities traditionally think the area
should be protected.

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Project Project Name and


Grounds and Verification Results of Applied Projects in Critical Natural Habitats
No. Country
Project implementation continuously.
(Vanuatu)
20 San Miguel Bypass Of 147 species of plants in 61 families identified at the project site, one species
Construction (Lonchocarpus phaseolifolius) is classified as "critically endangered" (endangered IA) by
IUCN Red List of Threatened Species (2011) for El Salvador. Appropriate measures such as
Project (El
transplantation will be taken.
Salvador)
33 Mumbai Trans- Though a part of the project passes through the tidal flat (Mahul-Sewri Creek) which is an
Harbour Link Important Bird Area specified by Birdlife International, the project does not significantly
Project (1) (India) affect the habitats of birds such as flamingos. Therefore, it is assumed that undesirable
impacts on the natural environment will not be significant by implementing mitigation
measures such as adopting the bridge design accommodating impacts on birds and
constructing noise barriers. The project conducts long-term and effective monitoring and
evaluation.
40 The Project for Part of the study area is wetlands and flood plains, and there are endangered species such as
Study on Integrated Vulnerable (VU) under the IUCN Red List. Although the area is a protected, it decided the
Development of the protected area is excluded from the F/S area after discussion between Paraguay government
Adjacent Zones to and JICA. High possibility of excluding the protected area from the F/S area supported by
the Yacyreta Dam JICA.
Reservoir
(Paraguay)
Source: Prepared by JICA Study Team

Case where "Protected Areas that are Specifically Designated by Laws or Ordinances for the
Conservation of Nature or Cultural Heritage" was Changed
In the 6th WG meeting for reexamination of JICA GL Operation, it was suggested that it is necessary
to recognize and to take a prudent action to the potential issues in which the project proponents etc.
change the legal status of "protected areas that are specifically designated by laws or ordinances for
the conservation of nature or cultural heritage" in order to implement the development projects.
These concerns have been sometimes raised at international conferences. In response to this
suggestion, the projects listed in this study were reviewed from that point of view, however there
was no such practice among the reviewed projects.
Examples of Natural Habitats paid Attention from the Aspect of "Local Community" and
"Social Environment"
Based on the recommendations in the 2nd and 6th WG meetings for reexamination of JICA GL
Operation, considerations from the aspect of "local community" and "social environment" for the
natural habitats were studied; however, such a practice was not identified in the review projects. In
the case of project No.41, as a reference, since the National Park, which is adjacent to the project
site, is the tourism resources and water source, SINAC (government body in charge of national
parks) and the project proponent jointly implement conservation activities. They also promote
environmental education in order to raise the environmental awareness of the community and to
foster them to be a park guide for tourists.
Reflection of Residents’ Comments in the Project Plans after Public Consultation Meeting
Based on the minutes of the public consultation meetings, the following table summarizes the
examples of projects in which the comments were received from the participants at the public
consultation meetings and were reflected by the project proponents etc. in project planning. Among

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90 projects, 70 projects carried out the public consultation meetings (excluding 6 projects with
Category FI [In No.43, this study confirmed that the meetings were conducted in subprojects], 10
projects with Category B which improve the existing facility and located in the existing project
[technical cooperation projects and the verification surveys under SME support projects only],
4 Technical Cooperation projects for Development Planning with M/P Implementation). In 30
projects, the public consultation meeting has not been conducted, and these include the master plan
study which conducts the consultation meeting at the SEA level, E/S and grant projects with
Category B in which SHM to be organized later, other Category B projects, Category C projects,
and Category FI projects. In 70 reviewed projects, the comments and opinions raised during the
public consultation meetings and their incorporation in planning are summarized in Table 2-11.

Table 2-11 Comments from the Public Consultation Meetings which were Reflected
Project Results after Incorporating
Project Name Comments
No. Comments
3 Turakurgan Thermal How many employments will be Employment of youth is reflected in
Power Station produced? the project plan
Construction Project
(Uzbekistan)
5 Delhi Mass Rapid It was pointed out that socially Additional measures for the women,
Transport System Project vulnerable groups such as women and elderly and disabled were
Phase 3 (India) elderly people should be considered at incorporated in the project.
the time of vehicle operations during
the Operation and Maintenance
(O&M) stage.
10 Central Luzon Link Concerned that the flow of rainwater Measures such as ditch and vertical
Expressway Project from the road rushes into participants’ drainage were incorporated in the
(Philippines) land design so that the condition did not
get worse by rainwater drainage from
the road.
17 Hanoi City Ring Road At the public consultation meeting Installation of noise barrier was
No.3 Construction Project held after the design change of the included in the plan.
(Mai Dich - South Thang viaduct, concerns about noise were
Long Section) (Viet Nam) raised.
20 San Miguel Bypass Width of bypass, streetlight Alignment of the bypass was shifted
Construction Project (El installation, impact on school, by 130 m in order to avoid the impact
provision of information, etc.
Salvador) on the school. Box culvert for
livestock crossing, and footpath on
the bridge across the Rio Grande de
San Miguel and Taisihuat Rivers were
installed, based on opinions of Project
Affected Persons (PAPs) and local
stakeholders.
41 Las Pailas II Geothermal a) Request for construction of a a) Construction budget of drinking
Project (Guanacaste common water supply. water pipelines is included in EMP
Geothermal Development b) Priority employment of Curubande b) It has already dealt with.
Sector Loan (Las Pailas II) community residents Employment of local community
(Costa Rica) c) Request for cooperation in residents will be monitored through
community infrastructure environmental monitoring.
constructions (construction of a c) Road maintenance and safety
dining room for children, construction measures (installing speed bumps and
of a multipurpose hall, improvement signs, inspection & measurement of
of kindergarten facilities, light vehicle speed) have been taken place.

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Project Results after Incorporating


Project Name Comments
No. Comments
installation for sports filed, d) Although no regional emergency
construction of wells for lawn plan has been prepared, the post-
irrigation, expansion of schools and operation health and safety
road improvement) environment plan (Plan de Salud
d) Presence or absence of local Ocupacional Planta Geotérmica Las
emergency plans. Pailas) has been prepared.
e) Possibility of soil contamination by e) Since the plant is operating in a
fuel used to operate the plant completely sealed system, there is no
possibility of such contamination
trouble.
42 Kenya-Tanzania Power Expectations for job creation and It was explained in the meeting that
Interconnection Project benefits to the communities by the their policy is to utilize local workers
(Tanzania) project and the project consists of
electrification of rural areas. Although
it was for the construction period, it
was confirmed in the field survey of
this study that many local residents
are employed for construction work
that does not require specialized
skills, and that women are also
employed at the contractor’s office
and engage in office works.
51 Borg El Arab International Renovation of the access road Renovate access roads from
Airport Extension Project Alexandria Desert Road, Alexandria
(Egypt) City, and Borg El Arab City.
64 Mini-Hydropower a) Landslides occur along roads and a) Conversion to the sugar cane fields
Development Project riverbanks during the rainy season is progressed in open land in the
(Laos) due to the geological characteristics upstream basin, and it is one of the
of this area. This is the cause of the causes of landslides and river
sedimentation of the Nam Woo River turbidity. The project proponent
and the turbidity of the river. Is there answered that these will be regulated.
any impact on this project? (residents) In “(4) geomorphology and geology”
b) Will it increase flood damage in of the environmental checklist,
upstream of the paddy field due to evaluated results say that (i) no
this project? (residents) reservoir is developed since the run-
c) Even in the past where there was off-the-river type power generation
no project, there has been flood method is used, and there would not
damage as a natural disaster, but is be concerns caused by the reservoir
there any chance that future flood such as sedimentation trapped by the
damage will be attributed to the reservoir which will reduce the
project? (residents) sediments inflow into the downstream
d) The contractor shall make an effort area, lower the riverbed, soil erosion,
to reduce the burden on the reduced capacity of a reservoir,
surrounding environment during increased riverbed in upstream area,
construction. In addition, they need to sedimentation, and (ii) as for concerns
secure funds for the construction of of a large scale modification, since a
facilities to drain the flood within the smaller dam will be constructed and
project area (District Public Project changes in the river flow are limited,
Bureau). there would be no significant negative
impact on geography and geology.
b) The project proponent responded
that they planned to minimize the
impacts. After predicting the impact,
it was concluded that 2.66 ha of
paddy fields along the river would be

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Project Results after Incorporating


Project Name Comments
No. Comments
inundated due to the flood that occurs
once in 100 years (design flood
frequency), and the crops to be
damaged will be compensated as per
the national law.
c) The project proponent responded
that in design stage, they would assess
the most likely impact. As previously
mentioned, the possibility of
flooding/inundation was expected.
d) It was agreed to make efforts for
reducing the impacts on the
surrounding environment. Although it
is not anticipated that discharging
flooded water is required due to this
project, by any chance, if it happens,
the issue will be considered by
Kabupaten and Kecamatan
governments. As mentioned above in
a) though drainage facility for flooded
water and its budget are not included
in the JICA preparatory study since
they are not identified as negative
impacts. However, as a part of the soft
components of the project, the
operation and maintenance manual
will be prepared for troubleshooting
during flooding, after flooding and
during emergency/down time, and the
capacity building training for the
project proponent will be provided.
Source: Prepared by JICA Study Team

Impact of Disasters on Projects and Examples of Dealing with Accidents at the Project
Implementation Stage
During the 7th WG meeting for reexamination of JICA GL Operation, the relationship between the
project and the disaster such as the impact of disasters to the project, and responses to the accident
at the project implementation stage, were discussed. They are categorized in 3 possible types,
namely (i) the project lowers the resistance of the project site and increases the disaster risks, (ii)
the project may directly trigger a disaster (e.g. Dam construction might induce earthquakes), (iii)
the project may indirectly trigger a disaster (e.g. Construction of a power plant might contribute to
global warming). It was suggested that it would not be desirable to exclude disasters from the scope
of the EIA. In response to this, the reviewed projects were examined whether there is a project that
falls under items (i) to (iii). As a result, the following two projects were confirmed as (i) the project
reduces the resistance of the project site and raises the disaster risk. No cases were found that
correspond to (ii) and (iii).

Table 2-12 Projects which Lower the Resistance of the Project Site and
Increases the Disaster Risk

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Project
Project Name Overview
No.
14 Mandimba- The risk of soil runoff due to embankment and cutting in mountainous areas is
Lichinga Road mentioned, and it is pointed out that it is necessary to take measures such as gabions
Upgrading Project and vegetation according to the preparatory study report.
(Mozambique) In addition, it is stipulated in the Environmental and Social Management Plan (ESMP)
to take appropriate mitigation measures for soil runoff as necessary.
35 Olkaria V It has been pointed out that landslides and soil creep may occur when embankment and
Geothermal Power cutting are conducted at places with steep slopes and weak ground according to the
Development ESIA.
Project (Kenya) In addition, it is stipulated in the ESMP that mitigation measures such as the
installation of retaining walls, the installation of barricades, and signs for danger
should be taken as necessary.
Source: Prepared by JICA Study Team

Good Practices and Issues for Consultation and Stakeholder Analysis


Regarding consultation with local stakeholders, among the Category A projects in which JICA is
supporting the preparation of EIA, consultations are conducted with local stakeholders at the
scoping stage and the DF/R stage of EIA. In the co-financed projects of No.24 North-South
Expressway Construction Project (Ben Luc - Long Thanh Section) and No.28 Batchenga - Lena
Road Project, EIAs have already been prepared before JICA involved, and it was confirmed by JICA
at the time of the appraisal that appropriate consultation was carried out with support of ADB and
AfDB in the past. In addition, the EIA was similarly prepared and approved in the case of No.16
Port Vila Lapetasi International Wharf Development Project in Vanuatu; however, since SHM
attendees at the time of EIA preparation were limited to the aid agencies (Australian Agency for
International Development: AusAID, JICA), government agencies, local governments, additional 2
SHMs have been conducted during the JICA Preparatory Study.

Table 2-13 shows good practices of consultation which were confirmed among the reviewed projects.
These are the summary of the public consultation meetings at the planning stage. Good practices of
consultation are identified such as SHMs were organized as many as possible in terms of the
frequency and places and the meeting was announced well in advance to increase people’s
participation. Additionally, it was also observed that the FGDs were organized and a meeting of
professional groups was arranged. Good practices were also observed in some projects due to more
project-related factors. For instance, a project proponent strongly felt that the public understandings
are essential for smooth project implementation based on the previous phase's experience, and the
importance of social development was deeply understood in the policies and experiences of the
provinces and administrative districts.

Table 2-13 Outline of Good Practice for Consultations


Project Content/Individual Factor
Project Name Classification
No. (If identified by review material)
1 Navoi Thermal Power Station Additional As a result of implementing the planned
Modernization Project implementation of SHM, it was considered that the information
SHM
(Uzbekistan) was insufficient, and additional interviews
and additional SHMs were implemented.
17 Hanoi City Ring Road No.3 Added the number of SHMs in response to

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Project Content/Individual Factor


Project Name Classification
No. (If identified by review material)
Construction Project (Mai Dich - the request from the residents.
South Thang Long Section)(Viet
Nam)
32 North East Road Network Added the number of SHMs in response to
Connectivity Improvement Project the request from the residents.
Phase I (India)
5 Delhi Mass Rapid Transport Prior consultation Carried out prior consultation with the
System Project Phase 3 (India) such as meeting date resident welfare association, shopkeeper
and place, etc.
association of applicable district on the
meeting date, time, and place

23 Jamuna Railway Bridge Detailed SHM Conducted 83 consultations (public


Construction Project(E/S) implementation consultation meetings, FGDs, face to face
(Bangladesh) interviews) from June 2017
29 Rengali Irrigation Project(Phase 2) Meetings were held at 132 locations
(India) targeting 507 villages between October
2012 and November 2013

32 North East Road Network Separately held discussions for the Bengali
Connectivity Improvement Project community with many informal occupants
Phase I (First Term) (India)
2 New Bridge Construction Project Reflection of Implemented SHMs in multiple times by
over the Kelani River (Sri Lanka) residents' opinions on various ways during the preparation of the
plans EIA and RAP. As a result, support for daily
labor and small self-employed workers was
included in the livelihood restoration plan,
and a relocation of 25 houses was avoided
by reexamination of the construction
method.
32 North East Road Network In order to avoid large-scale resettlement in
Connectivity Improvement Project densely populated areas, in the main four
Phase I (I) (India) villages, widening existing roads was
changed to construction of a new bypass.
2 New Bridge Construction Project Various meeting In addition to the public consultation
over the Kelani River (Sri Lanka) styles meetings, interviews by individual visits,
and FGDs for the groups of people who are
making the incense sticks, people who are
bathing in the Kelani River, three-wheeled
taxi drivers, school children were
conducted.
5 Delhi Mass Rapid Transport Informal meetings along the alignment, and
System Project Phase 3 (India) FGDs for residents’ groups, shops, and slum
dwellers were conducted.

7 The Kanchpur, Meghna, and Gumti Conducted multiple consultations with


2nd Bridges Construction and various stakeholders to improve
Existing Bridges Rehabilitation understanding of PAP requests and to
Project (Bangladesh) discuss on the compensation calculation and
compensation process with stakeholders.
24 North-South Expressway Separate consultations were held for
Construction Project (Ben Luc - households including socially vulnerable
Long Thanh Section) (Viet Nam) groups, such as female headed households
and households with the disabilities, and
special assistance was be explained.

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Project Content/Individual Factor


Project Name Classification
No. (If identified by review material)
26 Mumbai Metro Line 3 Project Informal meetings, public meetings, FGDs,
(India) and individual interviews were conducted.
31 Ahmedabad Metro Project (1) In order to hold a consultation meeting at
(India) the city level, the door-to-door visits, the
meetings for each residential unit, and
FGDs were conducted step by step.
33 Mumbai Trans-Harbour Link Informal group meetings on RAP,
Project(1)(India) stakeholder meetings, FGDs (including for
residents, shops, and slum dwellers),
individual interviews through the socio-
economic survey, and discussions with key
informants were conducted in order.
11 Pasig-Marikina River Channel Participation of 27 professionals participated from related
Improvement Project (Phase 3) diverse actors organizations such as Pasig River
(Philippines) (professional groups, Regeneration Committee and Non-
etc.) governmental Organizations (NGOs)
16 Port Vila Lapetasi International Identified and invited relevant government
Wharf Development Project agencies, municipalities, tribal chiefs,
(Vanuatu) shipping agents, users of the bay (fishery
officials, oil companies, resorts, hotels, and
tourists), and NGOs.
Source: Prepared by JICA Study Team

After explaining the draft interim report of this study to the Advisory Committee on January 11,
2019, the advisory committee suggested to review challenges in addition to the good practices of
consultation. Challenges of consultation in 2 projects are described in the table below as discussed
in the past Advisory Committee meetings.

Table 2-14 Example of Consultation Challenges


Project
Project Name Contents
No.
6 Dhaka Mass Rapid Transit Female participation was quite limited. There is a need for a system in which
Development Project (1) information is disseminated not only to residents’ leaders but also all
(Bangladesh) residents.
33 Mumbai Trans-Harbour Link There are concerns for holding discussions with the concerned fishery persons
Project (I) (India) in advance.
As a reference, the impact on the fishery persons (especially the impact on
smaller scale fishery or informal fishery persons) was also discussed for other
projects.
Source: Prepared by JICA Study Team

For the Category A projects which EIA and/or RAP have been prepared, the number of participants
per SHM was confirmed in each EIA, RAP, and both EIA & RAP.

・ The number of participants for EIA-related SHMs was mostly between 10 and less than 100
people (72% of SHMs). There are 5 consultation meetings (or 4 projects) which was
participated by more than 300 people at one time. Especially in Project No. 27, two public
consultation meetings were held with over 700 participants.
・ In RAP-related SHMs, 42% of SHMs was attended by 10 to less than 50 participants, and 73%
of the total was held by less than 100 participants.

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・ Among the reviewed projects, in 12 projects, SHMs were held both for EIA and RAP at the
same time. When SHMs for EIA and for RAP were held separately, it was confirmed that the
number of meeting participants tends to be smaller for RAP than that for EIA.
・ In the case of 6 linear infrastructure projects where potential meeting participants are scattered
along the project area (projects Nos.8,18,21,29,32,44), it was observed that SHMs for RAP
were held at more than 10 different locations.

500 - 1000 people


400 - 500 people
1 -10 people
300 - 400 people

200 - 300 people

100 - 200
people
10 - 50 people

50 - 100 people

Source: Prepared by JICA Study Team

Figure 2-3 Percentage of SHM Participants in EIA for Category A Projects

500 - 1000 people


400 - 500 people
300 - 400 people 1 - 10 people
200 - 300 people

100 - 200
people
10 - 50 people

50 - 100 people

Source: Prepared by JICA Study Team

Figure 2-4 Percentage of SHM Participants in RAP for Category A Projects


In addition, for projects in which multiple SHMs were held, the minimum and maximum number
of SHM participants were confirmed.

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・ Even in the same project, sometimes the number of participants varies greatly from time to
time. This was because both discussions with small groups such as FGDs and public meetings
such as SHMs were conducted.
・ In project No.27 Flood Risk Management Project for Cagayan de Oro River, SHMs for EIA /
RAP were held five times in total. In two of these meetings, the number of participants
exceeded 700 people. The reason for the large number of participants could be that local
residents have a fresh memory of the damage caused by the typhoon “Sendon” and were highly
interested in the river improvement project. Additionally, the SHM was held in Cagayan de
Oro, which has a large population.
・ Since the number of PAPs depends on the project, and the geographical distribution of project
PAPs varies greatly depending on nature of the project, it is difficult to set an appropriate
number of participants per meeting. Especially, in the case of linear infrastructure projects,
PAPs are more scattered than the non-linear projects such as the industrial park development.
Therefore, even if the number of participants is smaller, it can be considered more appropriate
to hold multiple meetings at places where the residents can easily access. In addition, in the
case where PAPs are concentrated in one place, if there are a large number of PAPs, meetings
were held at multiple times or held in a large venues. When it was held in a large venue, it was
expected that the PC projector would not be visible to all participants, so additional efforts
were made to distribute materials and increase the number of staff. In addition, sometimes time
is limited for questions and answers for the large meeting, a follow up action is necessary to
receive adequate opinions from participants such as individual discussions and small group
discussions.
・ As a stakeholder analysis method, there are various methods such as matrix, diagram and
brainstorming were adapted. For the reviewed project, the implementation of stakeholder
analysis was confirmed in 16 projects. Several common methods are summarized in
・ Table 2-15 accordingly.
For example, in the early stages of a project, the brainstorming was conducted with relevant
organizations and identified wider stakeholders from two perspectives: (1) those who have
influence or authority over the project, and (2) those who have interest in the success/failure of
the project or have influence on the project. Matrices and diagrams are also useful tools for
organizing and understanding the power relationships and interests between stakeholders.
Although it is a rather rare approach, for No. 1 Navoi Thermal Power Station Modernization
Project, Uzbekistan and No. 3 Turakurgan Thermal Power Station Construction Project which
are both in Uzbekistan, stakeholders were identified by the numerical calculation concerning
the environmental impact area. The method is considered effective and useful, if environmental
information such as weather conditions can be obtained at the stage of stakeholder analysis.

Table 2-15 Examples of Conducted Stakeholder Analysis

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Project
Project Name Contents
No.
7 The Kanchpur, Meghna, and Used a matrix and diagram and conducted brainstorming, FGD, and public consultation.
Gumti 2nd Bridges
Construction and Existing
Bridges Rehabilitation
Project (Bangladesh)
9 Matarbari Ultra Super Same as above
Critical Coal-Fired Power
Project(I)(Bangladesh)
15 Greater Cairo Metro Line Conducted brainstorming.
No.4 Phase1 Project (Egypt)
26 Mumbai Metro Line 3 It is carried out in the procedure of:
Project (India) Informal meeting → public meeting → FGD → individual interview → discussion
on important issues → sharing opinions of PAPs.
29 Rengali Irrigation Project When implementing EIA, SIA, Rehabilitation & Resettlement Plan, stakeholders are
(Phase 2) (India) identified by the Participatory Rural Appraisal (PRA), mapping, matrix, diagram, FGD,
village meetings, and one-on-one discussion, etc.
31 Ahmedabad Metro Project Conducted through individual meetings, public meetings, FGDs, and consultations with
(1) (India) relevant agencies by considering direct and indirect impacts.
40 The Project for Study on Stakeholder analysis was conducted by the local office of Department of Agricultural
Integrated Development of Promotion of Ministry of Farming (DEAg) and local governments with surveys by local
the Adjacent Zones to the governments and in consultation with residents. Stakeholders were categorized into
Yacyreta Dam Reservoir public sector, private sector and social organizations.
(Paraguay)
41 Las Pailas II Geothermal Based on Costa Rica's EIA law, the direct impact areas and indirect impact areas are
Project (Guanacaste identified. Stakeholders are usually identified by consulting with the Board of
Geothermal Development Education, which usually represents the residents, and the Development Association of
Sector Loan (Las Pailas II) the community.
(Costa Rica)
49 Greater Yangon Water Stakeholder analysis was conducted in consultation with Yangon City Development
Supply Improvement Project Corporation (YCDC) which is the implementing agency of the project.
(Myanmar)
Source: Prepared by JICA Study Team

Good Practice of Environmental and Social Considerations


While good practices on consultation are discussed for the reviewed projects in the previous section,
general good practices in terms of environmental and social considerations are summarized from
the projects other than the reviewed project in this section.

Table 2-16 Good Practices in Environmental and Social Considerations


No Project Name Contents
1 Colombo City Public Transport For alternatives considerations, concerns were identified from various
System Project (Sri Lanka) perspectives such as environmental and social considerations, access, demand,
and technical aspects and the alternatives were assessed from these aspects
carefully. Since this project passes through the areas next to the Srijayawardana
Bird Conservation Area and Tarangama Environmental Conservation Area, the
legal status and boundaries of the conservation areas were confirmed, SHMs
were conducted, the alternative options were carefully examined. As a result, a
route that does not pass the protected/conservation area was selected.
Alternative routes were also examined to minimize the impacts on the linden
and religious places that have a religious value in Sri Lanka.
2 Colombo City Public Transport When preparing mitigation measures such as compensation planting by this
System Project (Sri Lanka) project, trees that are easy to adapt to the local environment were selected in
consultation with researchers of a local university.

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No Project Name Contents


3 Nairobi Viaduct Construction The draft environmental monitoring plan with calculated monitoring costs is
and Road Improvement Project considered a good practice since it will ensure the implementation of
(Kenya) environmental monitoring. In order to further enhance implementation of
environmental monitoring, it was suggested by the advisory committee to
specify the cost for each environmental monitoring parameter.
Source: Prepared by JICA Study Team

Responding to Issues Raised by the Third Party


There were 5 projects in which environmental/social issues were raised to project proponents etc.
and/or JICA by the third party.

Table 2-17 Issues Pointed out to the Project Proponent and/or JICA by the Third Party
Project
Project Name Case
No
4 Thilawa Special Economic ・NGOs pointed out as follows:
Zone (Class-A Area) Affected people’s group of Class-A submitted the request letters to JICA, and
Development Project requested on 7 April 2014 to have a meeting with JICA on 23-35 April 2014;
however, JICA didn't reply and decided to invest in the development of Class-A
on 23 April 2014.
・Some affected families of Class-A who resettled said they were threatened by
the government by saying “Their house will be demolished if they don’t sign an
agreement document for resettlement and compensation” and “if affected people
want compensation for land, people have to go to a court”.
・Since 2014, NGO submitted letters and reports regarding categorization,
requests for meeting with JICA, and implementation of the Guidelines.
6 Dhaka Mass Rapid Transit A water logging problem (flooding due to the rise of the groundwater level) was
Development Project (I) pointed out by nearly residents of the north side of the Depot which was not
(Bangladesh) captured by the EIA stage. It has been solved by measures such as constructing
drainages.
9 Matabali Ultra-Super Issues were raised by an NGO regarding the flood damage in the community
Critical Coal-Fired Power near the project site, sedimentation of rivers near the project site, delay of
Project (I) compensation and livelihood restoration assistance by the project proponent,
(Bangladesh) and safety issues of residents due to heavy traffic of project related vehicles.
13 Indramayu Coal Fired ・Comments on the review of Indramayu Coal Fired Power Plant Project were
Power Plant Project (E/S) submitted by NGO in August 2017. In addition, the NGO pointed out since
(Indonesia) August 2017 that it is not appropriate to arrest the local residents who are
protesting against the project raised the national flag upside down.
・The NGO also pointed out as follows:
Though the affected people’s group pointed out issues on the project and
submitted letters showing objection to the project and JICA finance three times,
there was no response from JICA. After the fourth letter was submitted to JICA,
JICA Indonesia office had a meeting with the group. After that, one more letter
was submitted from the group, however there was no response from JICA.
19 Rades Combined Cycle While emission of air pollutants (NOx, SOx) was pointed out from the third
Power Plant Construction party, mitigation measures are already included in EIA.
Project (Tunisia)
Source: Prepared by JICA Study Team

Since the start of operation under the JICA GL, objection to five projects have been officially raised,
and two of them proceeded to the investigation by JICA examiners as per the objection procedures
of the JICA GL (Projects Nos.4 and 84). In either case, non-compliance with JICA GL was not
confirmed; however, the examiners advised to facilitate the solution of the raised problems in line
with JICA GL's philosophy.

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Table 2-18 Project for which an Objection has been Filed to JICA
Reception Project
Country and Project Name Current Status
Date No.
May 16, 83 Support for Agricultural Preliminary Investigation: May 17 to July 3, 2017
2017 Development Master Plan for Investigation Period: July 4 to November 1, 2017
Nacala Corridor in Investigation Report: November 1, 2017
Mozambique Opinion on the Investigation Report from the
Operational Department: December 1, 2017
Opinion on the Investigation Report from the President:
March 2, 2018
Opinion on the Investigation Report from the Requester:
May 21, 2018
September 26 Mumbai Metro Line 3 Project Preliminary Investigation: September 8 to October 6,
7, 2015 (India) 2015
May 25, 12 New Bohol Airport Preliminary Investigation: May 26 - June 26, 2015
2015 Construction and Sustainable
Environment Protection Project
(Philippines)
February 26 Mumbai Metro Line 3 Project Preliminary Investigation: February 11 to March 10,
10, 2015 (India) 2015
October 28, - Hanoi City Urban Railway Preliminary Investigation: October 29 to December 4,
2015 Non Construction Project: Nam 2014
reviewed Thang Long – Tran Hung Dao
project Section (Line 2) (I) (Viet Nam)
June 6, 4 Thilawa Special Economic Preliminary Investigation: June 7 to July 4, 2014
2014 Zone (Class-A Area) Investigation Period: July 5 to November 4, 2014
Development Project Investigation Report: November 4, 2014
(Myanmar) Opinion on the Investigation Report from the
Operational Department: December 1, 2014
Opinion on the Investigation Report from the Requester:
December 3, 2014
Source: JICA WEBSITE https://www.jica.go.jp/environment/objection.html

Consideration for the Socially Vulnerable Groups in the Reviewed Projects


Among 90 projects, 60 projects prepared the plan to consider socially vulnerable groups. Some
Grant Projects, Technical Cooperation, SME support, Other Projects (Private Partnership Projects:
No.98 to No.100) and FI projects were excluded from the review scope due to the nature of the
projects. Among the infrastructure development projects, several projects were excluded because
the project will be implemented within the existing facility’s premises.

Regarding assistance for the socially vulnerable groups, in general, there were mostly financial
assistance for income, food expenses, medical expenses, etc. Other distinctive consideration
examples are summarized in Table 2-19. Non-financial assistance for the socially vulnerable groups
includes skill training opportunities, employment matching, employment opportunities, and special
arrangement for housing in the resettlement site. In addition, non-monetary measures for specific
vulnerable groups include the priority employment for women, opening of bank accounts for women
so that female PAPs can receive compensation, and allocating the ground floor of housing in the
resettlement site to the people with disabilities.

Table 2-19 Cases of Consideration for the Socially Vulnerable Groups

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Project
Project Name Contents
No
1 Navoi Thermal Power A survey on socially vulnerable groups was conducted, and in accordance
Station Modernization with national rules, government livelihood restoration program, vocational
Project (Uzbekistan) training, employment opportunities, and financial support are provided.
(Socially Vulnerable Groups: 11 households are vulnerable, such as female
headed households, people with disabilities, the poor, the elderly, etc.)
5 Delhi Mass Rapid ・ According to the minutes of the meeting, informal occupants and small
Transport System Project shop owners also participated in the meeting and expressed their opinions.
Phase 3 (India) ・ In the consultation meetings, hope for compensation for structures owned
byinformal PAPs without a legal right to land was expressed, and it was
incorporated in the compensation/assistance policy for the lost assets.
7 The Kanchpur, Meghna, ・ Special allowance of 10,000 taka per family, compensation for affected
and Gumti 2nd Bridges assets, and employment as a construction worker with priority (short-term
Construction and Existing measures) were incorporated.
Bridges Rehabilitation ・ Technical training and others based on Livelihood and Income Restoration
Project (Bangladesh) Program (LIRP) (long-term measures).
8 National Road No. 5 Implementation of the Livelihood Recovery Program (LRP), financial
Improvement Project assistance (equivalent to USD100 per time), and provision of land to landless
(Battambang-Sisophon households were planned for vulnerable households.
Section) (Cambodia)
10 Central Luzon Link Special support was planned in the RAP, such as providing cash and training
Expressway Project with socially vulnerable groups.
(Philippines)
11 Pasig-Marikina River In the RAP, socially vulnerable groups (e.g. the poor, people without land
Channel Improvement rights, religious minorities, women, children, the elderly, people with
Project (Phase 3) disabilities) were defined, and in the entitlement matrix, “the Poor and
(Philippines) Socially Vulnerable Households Support Measures” were clearly stated. In
this project, all project affected households were informal occupants, so all
were treated as socially vulnerable groups.
15 Greater Cairo Metro Line The Resettlement Policy Framework (RPF) stipulates employment support by
No.4 Phase1 Project the project (including vocational training) and services to be provided by the
(Egypt) Social Security Bureau for the poor. The similar supports are considered in the
RAP as of May 2018.
18 National Road No.5 ・60 years old or older households, widows, people with disabilities, landless
Improvement Project (Prek people, the poor (Cambodia poverty line is "monthly income is less than $ 20
Kdam - Thlea Ma’am per person", and national poverty line is set/updated by the Ministry of
Section) (I) (Cambodia) Planning) were recognized as socially vulnerable households in the project
area.
•640 households fall into the socially vulnerable groups. (Households over
60 years old: 373 households, Widows: 278 households, People with
disabilities: 19 households, Landless people: 111 households, the Poor
households: 37 households *one PAH can be classified under more than 1
category)
・In addition to the livelihood recovery program, cash assistance of $100 will
be provided to each vulnerable household.
20 San Miguel Bypass For children who are 10 years old and less than 10 years old in the project
Construction Project (El area, women in childbearing age, the elderly, people with disabilities, etc. who
Salvador) are recognized as socially vulnerable groups, an option to build a house
through a construction company is provided.
21 National Road No.5 60 years or older households, widows, people with disabilities, landless
Improvement Project people, the poor (Cambodia poverty line is "monthly income is less than $20
(Thlea Ma'am-Battambang per person") were recognized as socially vulnerable households in the project
and Sri Sophorn-Poipet area. Information will be updated when Detailed Measurement Survey) is
Sections)(I) conducted. Cash assistance of $100 will be provided to each vulnerable
(Cambodia) household. In addition, these socially vulnerable households are eligible to the
livelihood restoration project along with “people who are greatly affected by

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Project
Project Name Contents
No
the project and relocated households”.
23 Jamuna Railway Bridge A focus group discussion is planned for the socially vulnerable groups such as
Construction Project(E/S) women with assistance from the E/S consultant, and discussion results will be
(Bangladesh) incorporated in planning.
24 North-South Expressway Following supports for the vulnerable groups are included in the Entitlement
Construction Project (Ben Matrix:
Luc - Long Thanh Section) ・Additional monetary support in line with government regulations
(Viet Nam) ・Additional support for house construction and livelihood restoration
assistance
27 Flood Risk Management ・Vocational training and employment support are provided to women and
Project for Cagayan de Oro people with disabilities.
River (Philippines) ・For the elderly, support programs from the community and neighbors.
・For people with disabilities, support for securing income through training,
employment, and sales of goods will be provided at a community facility.
29 Rengali Irrigation Project ・In RAP, FGDs with the Scheduled Tribe (ST)/Scheduled Caste (SC).
(Phase 2) (India) ・During the RAP survey, women were interviewed.
・Continuing the Tribal Sub-Plan Approach which is commonly provided to
the ST/SC in Odisha State.
30 North - South Commuter Each LGU will dispatch nurses and social workers to those who need special
Railway Project (Malolos – supports and a medical care before and during resettlement, as well as paying
Tutuban) (Philippines) the nuisance fee (total 10,000 pesos).
31 Ahmedabad Metro Project ・For affected socially vulnerable households, 1 person per household is
(1) (India) entitled to a vocational training opportunity. Training expenses will be paid
(including travel and food expenses).
・The ground floor of housing will be allocated to people with disabilities in
the resettlement site.
・The residents in the isolated village will be able to select their neighbors.
・Provide visual information for illiterate people.
32 North East Road Network At the various stages of the project, special attention was paid to women:
Connectivity Improvement ・Ensure that at least 1 woman is included in the field team of RAP and the
Project Phase I (I) (India) restoration plan implementation agency.
・Enable women to participate in the activities of this project and receive the
benefits as part of RAP .
・The project proponent prepares a ID card and bank account for women PAPs
and enable women to receive compensation in their own bank account.
・As a socially vulnerable group, support women to gain alternative income.
・In monitoring process, ensure women’s participation in evaluation so that
women's perspectives are reflected.
・For road construction, both men and women will be employed. Although
most women are expected to commute from their own house to the
construction site, if they stay at the labour accommodation on the
construction site, necessary safety measures are provided to prevent sexual
violence and harassment.
33 Mumbai Trans-Harbour ・People with disabilities have a priority and an option to select the ground
Link Project (I) (India) floor of housing in the resettlement site.
・Priority loan provision from the local investment fund (initial investment
support and other loans)
34 Engineering Services (E/S) ・Women in parenting age, the elderly, people with disabilities, children are
for Construction of Jakarta socially vulnerable groups as described in OP4.12 and Involuntary
Mass Rapid Transit East- Resettlement Sourcebook (WB, 2004). Provide cash compensation,
West Line Project (E/S) apartments and kiosks in the relocation site to these socially vulnerable
(Phase I) (Indonesia) groups.
41 Las Pailas II Geothermal Decide the date and time of public consultation meetings considering the
Project (Guanacaste availability of the female residents to promote women's participation.
Geothermal Development

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Project
Project Name Contents
No
Sector Loan (Las Pailas II)
(Costa Rica)
42 Kenya-Tanzania Power ・The Vulnerable People’s Plan (VPP) was prepared for minorities and
Interconnection Project disclosed on the JICA website.
(Tanzania) ・FPIC consultations are being conducted when VPP is formulated.
・Not to relocate the Barbaig tombs, instruct contractors not to kill snakes
which considered culturally significant, and make sure not to interrupt the
circumcising ceremony during the construction.
49 Greater Yangon Water Women are participating in the public consultation meetings and have an
Supply Improvement opportunity to speak.
Project (Myanmar)
52 Natural Gas Efficiency In ARAP, special consideration for socially vulnerable groups (such as the
Project (Bangladesh) elderly household head, people with disabilities, women headed households,
etc.) and implementation of the livelihood restoration support are being
considered.
53 Urban Transportation Line- Vulnerable people (e.g. women, children, the elderly, people with disabilities):
3 Development Project (1) Providing programs based on the need for PAPs such as health, education,
(Panama) support for people with disabilities, psychological support, etc.
57 Maternal, Neonatal and ・This project aims to install equipment and improve the service at the public
Child Health (MNCH) and medical facilities mainly used by the poor, so it will consider the
Health System improvement of the health care for the poor.
Improvement Project ・Support enabling environment where pregnant women can safely deliver a
(Bangladesh) child.
62 The Project for Flood Among the policies in the ARAP, there is a statement that "special support for
Disaster Rehabilitation and the socially vulnerable groups is provided." In addition, within the Entitlement
Mitigation (Cambodia) Matrix, payment of $100 per household is set as financial guarantee for the
socially vulnerable groups (female-headed households, the elderly, people
with disabilities, the poor) that will be affected by the project.
72 The Project for Among the PAHs, additional financial support will be provided to the socially
Reinforcement of Power vulnerable groups (under the poverty line of the WB, the elderly household
Supply to Accra Central head, people with physical disabilities).
(Ghana)
73 The Project for ・Around the school, provide a pedestrian lane for school children so that the
Improvement of Gulu construction does not hamper commuting. Ban on child labor at construction
Municipal Council Roads sites
in Northern Uganda ・Monitor gender and child rights issues through the GRM.
(Uganda)
75 The Project for the ・Approx. 10 people who make dried fish in an abandoned house in the project
Expansion of Fishing Port area are recognized as a socially vulnerable groups.
in Nouadhibou ・It will be confirmed whether the equivalent income will be obtained at an
(Mauritania) alternative site during the construction stage or through an alternative
livelihood mean during the operation stage.
79 The Project for The project will reduce the burden of women and children to bring water.
Augmentation of Water
Supply System in Narok
(Kenya)
80 The Project for Special attention to be paid to socially vulnerable groups (e.g. people with
Rehabilitation of Irrigation disabilities, orphans, age 65 years or older) during the asset valuation and
Facilities in Rwamagana compensation payment procedures.
District (Rwanda) Employment will be prioritized for socially vulnerable groups.
81 The Programme for ・Enhancing Poverty Alleviation: through efficient and smooth disaster
Rehabilitation and recovery by this project, promote recovery in line with “Build Back Better”
Recovery from Typhoon concept and contribute to regional economic growth and poverty alleviation.
Yolanda (Philippines) ・Enhancing Social Development: Construct facilities for the people with

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Project
Project Name Contents
No
disabilities at schools, such as special toilets and a slope to the second floor.
86 The Project for Capacity In El Salvador, there were many women participating in road construction,
Development of the and special arrangement for female workers are available such as changing
Department of Climate rooms and toilets for women. Such considerations shall be implemented in the
Change Adaptation and project in line with the government gender approach.
Strategic Risk Management
for Strengthening of Public
Infrastructure, Phase 2 (El
Salvador)
87 Capacity Development Poverty Alleviation: adopting a mechanism called LCS (Laboure Contracting
Project for Participatory Society) to outsource small-scale (minor) construction and maintenance works
Water Resources to organizations consist of socially vulnerable groups such as women.
Management through Gender Considerations:
Integrated Rural ・ Socially vulnerable groups are assisted and empowered based on "Gender
Development (Bangladesh) Equality Strategy and Action Plans 2008-2015” in Local Government
Engineering Department (LGED),
・ Integrated Water Resources Management (IWRM) unit, the counterpart of
the project, will have a full time sociologist in charge of gender and
development.
・ In Union Development Coordination Committee (UDCC) and Water
Management Cooperative Association (WMCA), more than 3 female
members are selected as per the regulations to ensure voices from women.
Source: Prepared by JICA Study Team

The following table summarizes the response to the advice on gender and children’s rights given by the
members of the JICA Advisory Committee in reviewed projects.

Table 2-20 Responses to Advice on Gender and Children's Rights


No. Project Name Contents of Advice Response and Results
1 7. The Kanchpur, Although child labor is The following contents were added for the consultation
Meghna, and Gumti prohibited in JICA project with parents and employers in Section 13), Chapter 8
2nd Bridges or by Bangladesh's national of EIA Report.
Construction and law, a F/S report should (1) School attendance support for children
Existing Bridges present specific assistance (2) Job support for parents (including employment of
Rehabilitation Project to be provided with parents parents at construction sites)
(Bangladesh) and employers in order to (3) Arrangement of microcredit
stop child labor in case it is (4) Introduction to supporting groups such as NGOs
found in construction work.
2 9. Matarbari Ultra Appropriate measures for Agreement was made with the project proponent not to
Super Critical Coal- the project proponent to have any labor contract with children, and to inspect
Fired Power Project prevent child labor should construction site regularly. Patrolling is done by the
(1) (Bangladesh) be included in the F/S project proponent and contractors during construction
report stage and by the project proponent does during
operation stage.
3 12. New Bohol Describe the policy to The policy to maintain appropriate gender balance for
Airport Construction maintain appropriate gender SHMs and results were described in the Final Report
and Sustainable balance during SHM and its (F/R) of the JICA Study.
Environment results in the final report. In addition, it was confirmed that 34 of 54 participants
Protection Project Also, apply this policy to were female PAPs for the SHM organized in April
(Philippines) SHM that will be 2012 to explain that resettlement by the airport
implemented in the future. construction in the future.
4 19. Rades Combined Information (including the The following information on the SHM was added in
Cycle Power Plant number of participants by the DF/R.
Construction and gender) should be added to 1 Number of participants by gender

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No. Project Name Contents of Advice Response and Results


Sustainable the draft final report.in 2 Women's comments
Environment order to help understand 3 Efforts by the project proponent to increase
Protection Project how comments from participation (especially women) and their results
(Tunisia) women and socially In addition, women's and socially vulnerable people's
vulnerable people are participation in planning in Tunisia and their comments
reflected into planning. on planning were added in the DF/R.
5 29. Rengali Irrigation Special considerations of Since the Odisha Pani Panchayat Act 2008 (Water
Project (Phase 2) gender and socially Users Association Law) requires 33% of participants to
(India) vulnerable groups in SHM be women, it was operated in a gender-friendly
needs to be included in the manner.
environmental review In addition, affected widow households are considered
results as much as they are socially vulnerable groups, and it is planned to
confirmed. implement the livelihood restoration program as part of
agricultural technical training in the operation stage.
6 32. North East Road Add that women will be Described in F/R as follows:
Network preferentially employed for “Of the employment opportunities that accompany
Connectivity jobs at construction work construction, women are preferentially hired for jobs
Improvement Project that women can perform in that can be done by women.” (Sections 6 and 7 in
Phase 1 (India) the F/R. Chapter 12)
7 Add that women's opinions Described in F/R as follows:
will be fully reflected in “Even in SHM during the RAP implementation stage,
SHM in the F/R of JICA participation of women's groups will be considered so
Study. that women's opinions are fully reflected” (Sections 6
and 7 in Chapter 12, F/R)
Source: Prepared by JICA Study Team

Changes of the Number of Project Affected Persons between the Environmental Review and
Monitoring Stages
Among the reviewed projects, there were 37 projects in which involuntary resettlement involved,
and the number of PAPs to be resettled was identified as an output of environmental review in all
these projects. Among them, the number of PAPs at the monitoring stage has been confirmed in
30 projects. The rest of 7 projects (Nos.15,28,30,34,47,53,73) have not been monitored since land
acquisition and resettlement have not yet started.

The number of PAPs increased in 7 projects and decreased in 4 projects, while other projects did
not see the change in the number. The reasons for the increase include design changes during
Detailed Design stage and the update of impact area specified through the detailed census survey.
When the number of PAPs includes people whose land is acquired but residential structures are not
affected, such information is included in Table 2-21.

Table 2-21 Changes in the Number of PAPs in the Environmental Review and Monitoring
Stages and Reasons

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Number of
Number of
PAPs at
Project PAPs from
Project Name Environmental Reason for Changes in the Number of PAPs
No. Monitoring
Review Stage
Results
(Note)
2 New Bridge 1,797 persons 1,741 persons Based on the design changes in the D/D stage, the
Construction detailed census survey revealed the decrease of
Project over the PAPs.
Kelani River (Sri
Lanka)
5 Delhi Mass Rapid 543 337 Based on the design changes in the D/D stage, the
Transport System households household detailed census survey revealed the decrease of
Project Phase 3 (1,373 (604 persons) PAPs.
(India) persons)
6 Dhaka Mass Rapid 1,040 persons 1,154 persons Based on the design changes in the D/D stage,
Transit additional affected households were identified
Development through the detailed census survey.
Project (1)
(Bangladesh)
9 Matarbari Ultra 2,361 persons 2,156 persons Based on the design changes in the D/D stage, the
Super Critical Coal- detailed census survey revealed the decrease of
Fired Power Project PAPs.
(I) (Bangladesh)
14 Mandimba- 157 187 Based on the design changes in the D/D stage,
Lichinga Road households households additional affected households were identified
Upgrading Project (983 persons) (1,082 through the detailed census survey.
(Mozambique) persons)
18 National Road No.5 1,072 1,370 According to the project proponent, the number of
Improvement households households households to be relocated was increased due to
Project (Prek Kdam changes in the width of RoW for the planned road
- Thlea Ma’am in D/D stage. Details are currently under
Section) (I) confirmation.
(Cambodia)
21 National Road No.5 810 773 The number of households to be relocated was
Improvement households households decreased due to change in the design at the D/D
Project (Thlea stage.
Ma'am-Battambang
and Sri Sophorn-
Poipet Sections) (I)
(Cambodia)
26 Mumbai Metro 2,744 2,888 Based on the design changes in the D/D stage,
Line 3 Project households households additional affected households were identified
(India) (6,867 (7,273 through the detailed census survey.
persons) persons)

31 Ahmedabad Metro 533 595 Based on the design changes in stations, etc. in the
Project (I) (India) households households D/D stage, additional affected households were
(2,132 (2,380 identified through the detailed census survey.
persons) persons)
33 Mumbai Trans- households 322 Based on the design changes in the D/D stage,
Harbour Link (1,272 households additional affected households were identified
Project (I) (India) persons) (1,332 through the detailed census survey.
persons)
52 Natural Gas 140 persons 177 persons Based on the design changes in the D/D stage,
Efficiency Project additional affected households were identified
(Bangladesh) through the detailed census survey.
Note: The number of PAPs indicated as a result of environmental review is the number of physically displaced persons.

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Source: Prepared by JICA Study Team

Project that Mentions the Replacement Cost of Compensation


Of 37 projects where resettlement occurs, in all cases, the payment of compensation at full
replacement cost along with the specific calculation method was agreed based on RAP of projects
and discussions at the time of appraisal.
Projects for which GRM has been Established
Among the reviewed projects in which the land acquisition occurs and fall under the Category A
and B, 43 projects out of 44 established the GRM for land acquisition and resettlement in the project.
The remaining 1 project (No.34) is excluded because the E/S loan had been provided but land
acquisition has not been started. In addition to this, the GRM for non-resettlement issues such as
noise caused by construction work was established in 11 projects which does not involve involuntary
resettlement.

GRM is established at various levels from the village level, local government level, to higher levels
such as prefecture and province levels. In general, if the issue is not solved at the lower level, it will
be taken to the higher-level mechanism. In addition, in many cases, PAPs or local resident can seek
a resolution in the judicial process, if the person are not satisfied with the decision of the project
GRM (GRM does not prevent from utilizing other problem-solving options). This review confirmed
the following; establishment of a project-specific GRM besides the host country's existing judicial
process (because the judicial process takes longer time and has issue of credibility); participation of
PAPs, women, tribal representatives, NGOs in the GRM; and improved availability of the GRM
were confirmed in this review study.
Development of IPP
The review found that IPPs are often prepared in forest conservation projects. Impacts on indigenous
peoples settlements were confirmed in 3 projects (Nos.32,42,44). In the project area of No. 32 North
East Road Network Connectivity Improvement Project Phase 1 (I), ST (designated tribe) that falls
under the definition of “indigenous peoples” in OP4.10 of the WB were identified. Following the
WB OP4.10, JICA GL consider people with the following characteristics in various degrees as
indigenous peoples (WB OP4.10 July 2005).
a. self-identification as members of a distinct indigenous cultural group and recognition of
this identity by others;
b. collective attachment to geographically distinct habitats or ancestral territories in the
project area and to the natural resources in these habitats and territories;
c. customary culture, economy, social, or political institutions that are separate from those
of the dominant society and culture;
d. an indigenous language, often different from the official language of the country or region.
PAPs in the project area of No. 32 the Northeastern Province Project fall in the above definition of
indigenous peoples. They possess their own identities and languages as Mizo (National Route 54)
and Garo (National Highway 51). However, in the project area where the majority of population is
Mizo-Garo tribes, it is not possible to say that they live under “a system different from the

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mainstream society and culture”. In India, designated tribes including Mizo and Garo are recognized
as indigenous peoples in their procedure in India, but in this project, almost all PAPs are Mizo and
the socio-economic survey has confirmed that their lifestyle and standard of living were the same
as that of people other than Mizo. Therefore, it was decided that IPP was not prepared separately
but the RAP included elements of the IPP, two public consultation meetings were conducted
considering Free, Prior, Informed Consultation (FPIC), and the basic agreement was reached (RAP
consisting of IPP elements was also prepared in the projects financed by ADB and WB in the same
state).

In No.42 Kenya-Tanzania Power Interconnection Project, Barbaig tribes identified in the project
area were considered as indigenous peoples. However, since the Tanzanian government does not
recognize any indigenous peoples in their own country, VPP instead of IPP was prepared and
published on the JICA website. During VPP preparation process, consultation meetings were
conducted based on the principles of FPIC. At the time of the field survey of this study in April 2019,
it was confirmed that VPP was appropriate since the schedule of the implementation of VPP was
consistent with ESMP, and the mitigation measures (e.g. tombs should not be relocated, snakes
should not be killed, and circumcision rituals should not be disturbed) mentioned in the consultation
for VPP were reflected in ESMP. Moreover, it was confirmed that mitigation measures not to kill
snakes and not to disturb rituals were reflected in the contractor’s contract as not to kill any animals
and respect the local culture.

No.44 Joint Feasibility Study for Mumbai-Ahmedabad High Speed Railway Corridor in India has
affected designated tribes within the project area, and the IPP framework was prepared.
EIA Process of Category A Projects Categorized due to Large-Scale Involuntary Resettlement
According to JICA GL, even if a project does not fall under a sensitive sector that are likely to have
a significant adverse impact, it is classified as Category A if it has a sensitive characteristic such as
large-scale involuntary resettlement, or it is located in a sensitive area.

It was confirmed that there were 6 projects (Nos.2,7,11,27,28,38) that did not fall under sensitive
sectors but had sensitive characteristic as large-scale involuntary resettlement, and were categorized
as Category A. Thus, the EIA was prepared in all 6 projects according to the requirements of JICA
GL for Category A project; however, in practice, an extent of impacts on environment was not large,
and some projects were not required to prepare EIA in accordance with national laws of host
countries.
Relevance of sensitive sectors
Among sensitive sectors as per JICA GL, 3 sectors namely “power transmission line/distribution”,
“water supply, sewage, and wastewater treatment” and “agriculture” have additional threshold
criteria for categorization in addition to “large-scale” as shown in parentheses below.

・ Power transmission and distribution lines (involving large-scale involuntary resettlement,

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large-scale logging, or submarine electrical cables)


・ Water supply, sewage, and wastewater treatment (having sensitive characteristics or located in
sensitive areas or in their vicinity)
・ Agriculture (involving large-scale land clearing or irrigation)
Among the reviewed projects, there is 1 project of “power transmission and distribution lines” and
3 projects of “agriculture”. All of them meet the sector-wise criteria for Category A. Further, they
were categorized considering sensitive characteristics and sensitive areas, and projects with
significant impacts were classified as Category A.

Table 2-22 Project Categorization in Power Transmission and Distribution Line Sector and
Agriculture Sector
Project Justification for Category A among “Power Transmission
Project Name Categorization
No. and Distribution Line” and “Agriculture” Sectors
Transmission and distribution sector
42 Kenya-Tanzania Power A The project falls into the power transmission and
Interconnection Project distribution lines sector and located in a sensitive area
(Tanzania)
Agricultural sector
29 Rengali Irrigation Project A The project falls into the Agriculture involving large-
(Phase 2) (India) scale land clearing or irrigation sector (located in a
sensitive area and is likely to have significant adverse
impact due to its characteristic)
40 The Project for Study on A The project falls into the agriculture sector and is likely
Integrated Development of the to have significant adverse impact due to its
Adjacent Zones to the Yacyreta characteristic
Dam Reservoir (Paraguay)
45 The Project on Irrigation A The project falls into the agriculture sector located in a
Scheme Development in Central sensitive area
and Eastern Uganda (Uganda)
Source: Prepared by JICA Study Team

Projects whose Livelihood Recovery is being Monitored


Among the reviewed projects, monitoring of livelihood restoration needs to be carried out in 31
projects, while 6 projects were not subject to monitoring (Nos.1,44,46,62,70,73). Among the
projects that are not subject to the monitoring, 2 projects (Nos. 1, 70) were excluded since there is
no change in the livelihood, another 2 projects have relatively small scale resettlement (No.73: 1
households; and No. 62: 4 households and relocation of 19 stores), and 1 project (No.46) has no
RAP but land acquisition and resettlement are in a process as per the national law and JICA GL.
Another 1 project (No.44) was excluded since it is a technical assistance project and the M/P is
being prepared.

Among the 31 projects for which livelihood restoration monitoring was planned, monitoring activity
has started in 19 projects, and not yet started in 12 projects. The results of the monitoring are
summarized below.

Projects that have agreed to disclose social monitoring results and which livelihood restoration is
being monitored (The rest of 5 projects have no agreement on disclosure):

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・ No.26: Mumbai Metro Line 3 Project, India


(1) Conducting industry-related skills training for young workers at 1 company, (2) Conducting
vocational training for young workers with weak economic conditions (training on electricity,
furniture repair, etc.) at 2 companies.
・ No.80: The Project for Rehabilitation of Irrigation Facilities in Rwamagana District, Rwanda
Although there are records on the progress of land acquisition and received complaints in the
monitoring results, no data on livelihood restoration was included. It is expected that it will be
described from the next monitoring report.
Among the reviewed projects in which the field survey was conducted, the findings on livelihood
restoration assistance was summarized below:

・ No.5: Delhi Mass Rapid Transport System Project Phase 3, India


External monitoring was carried out to check the livelihood restoration program, and no
particular problem was reported regarding the relocation site and livelihood restoration.
・ No.13: Indramayu Coal Fired Power Plant Project (E/S), Indonesia
From October 2016 to August 2018, 300 people participated in the livelihood restoration
program of "agricultural skills-based," and "non-agricultural skills based". This program is
being provided continuously. In addition, except for land acquired for access roads and
substation sites, farming is still allowed.
・ No.24: North-South Expressway Construction Project (Ben Luc - Long Thanh Section), Viet
Nam
In addition to compensation for affected assets at full replacement cost, provision of support
for the aquaculture of shrimp or livestock such as pigs, and support for initial livelihood
capacity building such as vocational training were provided according to PAPs’ preference.
The progress has been monitored every quarter. In Gan Gio area, where the livelihood
restoration support was firstly implemented, there were some PAPs who exchanged shrimps
and pigs with cash and used for other purposes. Therefore, in the future implementation of the
livelihood restoration support, it will strengthen consultation and training for the eligible PAPs.
・ No.36: Infrastructure Development Project in Thilawa Area Phase I, Myanmar
According to the RAP, the port development component planned to promote job opportunities
for PAHs before or after construction works upon request as a part of the livelihood restoration
program. However, there was no request from PAPs after compensation payment. As a result,
no livelihood restoration activity has been implemented.
・ No.42: Kenya-Tanzania Power Interconnection Project, Tanzania
As livelihood restoration support measures, i) rural electrification, ii) renovation of access road
near Arusha substation, iii) provision of wells were agreed with the project proponent at the
timing of the appraisal. The field survey found that: i) Rural electrification: There is a package
of rural electrification in the contractor contract and the contract has been concluded. Currently,
the areas to be electrified are being identified, ii) Renovation of access road near Arusha
substation: construction started on 15 April, 2019, iii) Provision of wells near Arusha

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substation: It was reported that the water supply was already prepared by the government
around Arusha Substation.

2.2.5 Case Analysis of Ayago Hydroelectric Power Plant Development Project

Project Background
“Ayago Hydropower Plant Development Project (Preparatory Study for Cooperation)” is classified
as Category A because it involves a large-scale hydropower project, and the study was launched in
2012. Since the project was planned within the National Park site, discussions were held on the
handling of the project implementation in protected areas under JICA GL.

Table 2-23 Discussion and Situation at the Advisory Committee


Date of Advisory Discussion and Background
Committee Meeting
General Meetings on May At the 24th and 25th general meetings, JICA provided briefings on the project. Among these,
11, 2012 (24th meeting) there was a debate on "implementation of development projects in national parks".
and June 4 (25th meeting) (General meeting on May 11, 2012)
(Explanation of Project http://www.jica.go.jp/environment/advice/pdf/giji/advice24_gijiroku.pdf
Summary) (General meeting on June 4, 2012)
http://www.jica.go.jp/environment/advice/pdf/giji/advice25_gijiroku.pdf
(https://www.jica.go.jp/environment/advice/pdf/giji/advice25_data02.pdf)
June 15, 2012 Prepared the draft advices.
(WG on draft scoping) (WG meeting on June 15, 2012)
https://www.jica.go.jp/environment/advice/pdf/giji/uga02_SCO_giji.pdf
General Meeting on July Discussed the draft advice. The main issues were the following three points. Additional
6, 2012 (26th meeting) explanation was provided by JICA.
1. Area 1 where the project locates is recognized as protected area, hence implementation
of a development project is prohibited in principle in accordance with JICA GL. Do you
have sufficient reasons for recognizing this case as an exception?
2. Since the JICA GL have been disseminated to the world, compliance with the GL also
attract attention from overseas and accountability of the operation are inevitable, and a
reasonable rational for “the exceptional case” is necessary.
3. Whether it is reasonable to proceed the preparatory study to find out if the project could
be the exception. Can we obtain the expected outcome if we conduct the study?

It was agreed to continue finalizing the advice at the general meeting.


After this meeting, discussions by e-mail were held within the WG, and discussions by e-
mail at the general meeting.
(General meeting on July 6, 2012)
https://www.jica.go.jp/environment/advice/pdf/giji/advice26_gijiroku.pdf
General Meeting on Finalized advice on draft scoping.
August 6, 2012 (27th “Because this is the development project in the protected area, it is urgent to re-examine
meeting) the appropriateness of this project from various perspectives such as the framework of
international protected area, national regulations for the protected area, frameworks for
resource use and development in Uganda, and the JICA GL. Considering these
frameworks and based on the attitude of the Environmental and Social Considerations
Committee to this subject, advices are provided in the following three areas:
A. Advice on discontinuing the preparatory study (hereinafter referred to as the study),
B. Advice to suspend the study and recommend to verify appropriateness of the project
implementation,
C. Advice on the study”
These advices were finalized.
4 members of the committee considered that cooperation to this project violates the JICA
GL and abstained from joining the committee members of this advices.

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Final Report
JICA Study for Review of JICA Guidelines for Environmental and Social Considerations February 2020

Date of Advisory Discussion and Background


Committee Meeting
The details of the above-mentioned process were disclosed on JICA website, including the
minutes of meetings.
(General meeting on August 6, 2012)
https://www.jica.go.jp/environment/advice/WG_others.html#africa
WG on August 9, 2012 Explaining the background to consider the advices
https://www.jica.go.jp/environment/advice/WG_others.html#africa
40th General Meeting on As a result of discussions with the Uganda government regarding this project, JICA
October 7, 2013 reported that the study will not be continued due to low possibility for Uganda government
to submit the request for JICA loan.
(https://www.jica.go.jp/environment/advice/ku57pq00000ngjcu-att/advice40_gijiroku.pdf)

Source: JICA website

In addition, at the reexamination of JICA GL Operation conducted in 2015, WG meetings were held
for each issue, and the results were compiled as “review results” based on the advice of the WG
meetings.

In relation to the project, the conditions that needs to be met when JICA assists a project in a
protected area as an exceptional case were discussed at the 6th WG meeting on "considering the
environmental and social impacts on ecosystems" (environmental and social considerations method)
on 28th November 2014 which reviewed the JICA GL’s operational aspects. This WG meeting
clarified points to be considered when deciding the implementation of a JICA project in “areas
designated by the government for the purpose of nature protection and cultural heritage protection
by laws and regulations”, etc. and these points were added to the FAQ disclosed on JICA website.
(The details are disclosed on the JICA website:
https://www.jica.go.jp/environment/guideline/review.html )

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Table 2-24 Responses to Advisory Committee’s Advices at the Implementatio20ge

JICA Study for Review of JICA Guidelines for Environmental and Social Considerations
Final Report
Project Advice
Project Title Advice to JICA JICA’s Confirmation Result at the Implementation Stage
No. Number
3 Turakurgan Thermal 1 Provide technical guidance to and confirm with the JICA requested the project proponent to treat domestic wastewater properly and to
Power Station project proponent so that BOD in wastewater from conduct environmental monitoring for wastewater. JICA also requested the project
Construction Project the plants and employees' facility will be properly proponent to confirm and monitor the impact when wastewater contains heavy
(Uzbekistan) treated. If the wastewater contains heavy metals etc., metals, etc.
request the project proponent to confirm the impact At this stage of construction work, JICA confirmed that the wastewater from the
and appropriate measures by monitoring, etc. plant and the employees’ facility was properly treated. As a result of monitoring,
no particular impact has been confirmed.
With regard to heavy metals, it was confirmed that the river water which will be
used as cooling water contains a small amount of iron and copper, but this is far
below the standards of IFC's EHS guidelines, and we have confirmed that in EIA,
the predicted value through the cooling system is also below the standard of the
EHS guidelines. To make everything assured, heavy metals are included in the
environmental monitoring item during the operation stage.
5 Delhi Mass Rapid 4 In the first paragraph of Section 6.5 of the EIA Based on this advice, JICA confirmed at the time of the project appraisal that
Transport System report on page 6.30, a lack of environmental EMP includes a provision of environmental education to workers. In addition,
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Project Phase 3 awareness among engineers and managers concerned monitoring results show that environmental education was provided to workers.
(India) with day to day construction activities during
implementation of environmental management plans
was raised, and regular environmental training
programs were suggested. Therefore, it should be
confirmed that the concrete measures are stated in
the EMP.
5 Delhi Mass Rapid 5 The construction work is carried out in dry season, JICA confirmed on this advice at the time of the project appraisal. According to
Transport System and dusts generated during construction and the monitoring results, the air quality measurement results such as dust were
Project Phase 3 transportation are considered to have a negative within the standard value and water sprinkling was regularly performed, and there
(India) impact on the surrounding residents. It is requested was no particular problem confirmed.
to investigate the dust amount and its dispersion
area, and make sure that mitigation measures are
planned if necessary, and that these measures are
planned to be informed to surrounding residents.

Feburary 2020
5 Delhi Mass Rapid 6 It is expected that the water use of the nearby We confirmed on this advice at the time of the project appraisal. We have
Transport System residents will be negatively affected when the confirmed that water use is included in the EMP.
Project Phase 3 project uses water from the drilled well and public Several mitigation measures were formulated such as storage and use of
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No. Number
(India) water supply. From this standpoint, it is requested to rainwater, reuse of wastewater, and thorough water conservation to mitigate the
ensure that detailed mitigation measures have been impact of fresh water use by the project. The results of mitigation measures were
developed for the negative impacts associated with disseminated to surrounding residents at stakeholder consultation meetings at the
the high volumes of water use, and that the project appraisal stage. In addition, it has been confirmed that water consumption was
proponent has plans to inform surrounding residents recorded in monitoring reports, and negative impacts on water use in the
of the water use. surrounding area have not been reported.
5 Delhi Mass Rapid 7 For the expected excavated soil of 13.17 mil. m3 for It was confirmed on this advice at the time of the project appraisal. The amount of
Transport System this project, it is planned that 2.42 mil. m3 is used in excavated soil is included in the environmental management plan and monitored.
Project Phase 3 landfills for the station and depot sites, and Excavated soil was used for landfills, discarded at the disposal site which was
(India) remaining 10.75 mil. m3 is to be treated in an designated by Delhi Metro Rail Corporation Ltd. (DMRC), and collected by a
environmentally friendly manner (EIA 4.5.3 on Page registered vendor. It was also confirmed that a blackboard was set up to record the
4.9). The method and place of this treatment should amount of waste discharged at the construction site and that result was disclosed.
be specifically decided, and the impact on natural
and social environment should be assessed, and if
any negative impact is expected, the mitigation
measures should be formulated and planned to
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disclose to public.
5 Delhi Mass Rapid 12 Since it is planned that the summary of SIA report is It was confirmed in the project appraisal that the project affected residents,
Transport System to be prepared in Hindi and distributed to all project including those who are illiterate, were explained about the project in the
Project Phase 3 affected residents, it is suggested to make sure that stakeholder meeting based on the Social Impact Assessment (SIA) report.
(India) an additional information disclosure measure is taken Informal consultations such as focus group discussions and individual interviews
for those who are illiterate can understand the with PAPs were also conducted. The summary of the SIA report has been
contents. prepared in Hindi and distributed to the project affected residents.
5 Delhi Mass Rapid 15 It is mentioned that project affected residents who It is confirmed that approximately 30% of the project affected residents were
Transport System lose their livelihood and socially vulnerable groups hired by the contractor(s). In addition, it was confirmed with the project proponent
Project Phase 3 are to be prioritized for job opportunities and that project affected residents will not lose their employment opportunity due to
(India) vocational training opportunities at the construction low educational background, lack of connections with influential persons, and the
stage. It is requested to make sure that those who are illiterate.
entitled are not discriminated due to low educational
background, lack of connections with key persons or
the illiterate, etc.

Feburary 2020
5 Delhi Mass Rapid 17 Since it is planned that eligible (vulnerable) PAPs It was confirmed that DMRC hired the NGO for the purpose of carrying out the
Transport System are able to receive vocational training to improve livelihood restoration assistance (rehabilitation assistance) for project affected
Project Phase 3 their skills, please further clarify the type and residents and provided information and advice to project affected residents on
(India) contents of training and ensure this plan will be various job opportunities and training. In addition, it was confirmed that the
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Project Title Advice to JICA JICA’s Confirmation Result at the Implementation Stage
No. Number
disseminated to PAPs. project affected residents include small-business owners such as small shops,
carpenters, tailors, and tea shops, and technical occupations such as electricians,
welders, car shops, and bicycle shops. Since these PAPs will continue their
current occupations and they do not need to take the vocational training, the
training was not formally conducted for them. It is confirmed that enough
employment opportunities are provided to PAPs by the project. For instance, as
mentioned above, around 30% of the project affected residents were hired by the
contractor, and other PAPs are also engaged in related work of the project.
6 Dhaka Mass Rapid 2 Regarding noise and vibration, at both construction For noise and vibration during construction and operation stages, mitigation
Transit Development and operation phases, the project should set up measures such as installation of silencers for construction equipment, installing
Project (1) appropriate measurement points where noise and noise barriers, adjustment of the departure bell volume, and low speed operation
(Bangladesh) vibration can be measured for regular environmental on curve are planned. At the time of the project appraisal, it was agreed with the
inspection/monitoring and the monitoring duration project proponent that as an additional mitigation measure to reduce noise and
with an appropriate frequency (esp. during vibration, use of a long rail would be considered at the time of detailed design, and
operation). additional protection measure(s) will be taken by the project proponent in case of
complaints.
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At the time of construction and operation stages, it was confirmed that the project
proponent set up appropriate monitoring sites, frequency, and periods at depots,
stations and other related facilities along the railway line, and carried out regular
monitoring. More specifically, noise level is monitored at the same monitoring
points every three months. At several points, noise level was observed above the
standard at several points, which were mainly influenced by the background noise
level; however, JICA requested the project proponent to implement mitigation
measures near sensitive receptors such as hospitals and schools which require
silence.
Vibration has not been monitored on a regular basis, but the contractor has
conducted the measurement, and it was confirmed that the measured results were
within the allowable value. In particular, in the case of land reclamation
construction (the work has already completed) which generally causes large
vibration, the contractor monitored the vibration level in daily basis. There has
been no complaint concerning noise or vibration. In addition, monitoring will be

Feburary 2020
conducted once every six months for two years after operation.
6 Dhaka Mass Rapid 4 Regarding the environmental inspection/monitoring For air quality, appropriate monitoring points were set up such as depots, stations,
Transit Development of air and water quality, the project should set up facilities and roads along the Mass Rapid Transit (MRT) route. The environmental
Project (1) appropriate measurement points, measurement monitoring plan during the construction stage specifies monitoring once a quarter.
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(Bangladesh) frequency and measurement period so that the status As a result of monitoring, it was confirmed that Particular Matter 2.5 (PM2.5) and
of air pollution and water quality along the MRT Nitrogen Dioxide (NO 2) levels exceeded the standard at several monitoring
route can be properly monitored. In particular, the points, and JICA requested the project proponent to implement mitigation
measurement should be continued during the measures such as regular maintenance of construction equipment and cleaning the
operation stage. road surface, taking into consideration the influence of background values.
Regarding water quality, it was confirmed that the project has set up appropriate
monitoring points such as depots, stations, ponds along the MRT route and
drainage ditches. According to the environmental monitoring plan during the
construction stage, monitoring of water quality is conducted once a quarter. As a
result of monitoring, it has been confirmed that the monitoring results of pH, Total
Suspended Solidas (TSS), etc. exceeded the standard at several monitoring points,
and JICA requested the project proponent to implement mitigation measures such
as wastewater pretreatment, taking into consideration the influence of background
values.
In addition, monitoring of air quality and water quality will be conducted once
every six months for two years during the operation.
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10 Central Luzon Link 2 For pollution-related mitigation measures, JICA ・ When JICA requested continuous monitoring to DPWH, it was confirmed that
Expressway Project should request the project proponent (Department of the following monitoring systems have already be in the place which were
(Philippines) Public Works and Highways: DPWH) to conduct initiated by DPWH.
environmental monitoring for a considerable period 1. Self-monitoring by DPWH
of time during the operation and to take necessary 2. Joint monitoring with local municipalities, etc. (Multi-partite monitoring)
measures, if necessary. 3. External Environmental Audit by the Department of Environment and Natural
Resources (DENR)
Regarding this project, above Nos. 1 and 2 are the main monitoring activities
during construction, but at the time of operation, it was confirmed that the
Concessionaire is in charge of monitoring. However, DENR has the right to
conduct environmental audits at any time during construction and operation stages
as stated in No. 3.
・ JICA confirmed with DPWH during this project appraisal that DPWH provides
pollution-related information to DENR at any time.
・ From the above mentioned monitoring system, it was confirmed that continuous

Feburary 2020
monitoring has been incorporated into the existing system initiated by DPWH for
pollution mitigations.
・ At the construction stage, based on the agreement at the time of the project
appraisal, it was confirmed that pollution-related monitoring such as air, water,
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No. Number
noise and waste was being carried out. Since some measured values of air (dust)
and noise were exceeded the standard value, JICA requested DPWH to confirm
the implementation status of mitigation measures. In addition, it was confirmed
that monitoring by the Concessionaire will be conducted at the time of operation.
10 Central Luzon Link 3 At the D/D stage, JICA should confirm with DPWH ・JICA agreed with DPWH that DPWH will make a mass diagram describing the
Expressway Project to consider the in-out flows of construction materials in-out flows of construction materials and the consultant will review it. JICA
(Philippines) involved in road construction such as excavated soil confirmed that this mass diagram review and implementation of the necessary
and soil for embankment, take necessary measures measures are described in the Terms of Reference (TOR) of the consultant for the
and specify these measures in the specifications of D/D.
the contract agreement.
10 Central Luzon Link 8 Among the project affected residents, there are Public consultation meetings with project affected residents have been conducted.
Expressway Project households that do not agree on resettlement and In the meetings, JICA confirmed that contents of compensation and others were
(Philippines) households that have not yet consulted. For these explained and no particular objection was raised. It was confirmed that DPWH
projects affected residents, please confirm with and local governments will (1) study the needs of the residents and (2) provide
DPWH that project affected residents will adequate information to the residents in the further stage of the project.
understand fully on specific impacts and As specified in the advice, JICA also confirmed that DPWH explained to the 4
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compensation methods through the public groups each and no issue was identified.
consultation in early November and the study and
consultation in the D/D stage, and DPWH will
proceed after reflecting their needs into the
compensation methods. During this process, special
attention needs to be paid to the following groups:
(1) Residents who have expressed opposition to
resettlement;
(2) Lease farmers and tenant farmers;
(3) Project affected residents with agricultural land
(TYPE B) who are involuntarily choose cash
compensation and relocate their houses due to loss
of farmland; and
(4) Among the farmers whose houses will be
affected by the project, especially the poor farmers

Feburary 2020
10 Central Luzon Link 9 Please confirm with DPWH that infrastructure such DPWH has secured the budget for infrastructure development such as electricity
Expressway Project as electricity and water supply will be developed at and water supply at the relocation site. Regarding the institutional arrangement for
(Philippines) the relocation site. construction of the resettlement site, JICA confirmed that the responsibility of
relevant government organizations will be decided after discussions with local
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Project Title Advice to JICA JICA’s Confirmation Result at the Implementation Stage
No. Number
government of the relocation site and National Housing Authority (NHA). As for
the implementation status, it was confirmed that infrastructure development such
as power and water supply in the relocation site was under arrangement.
10 Central Luzon Link 10 As for the relocation site (if required), JICA should ・In consultation with the residents to be displaced, it was confirmed that a
Expressway Project recommend DPWH to confirm the preference of relocation site in a good locational condition was requested, and that the relocation
(Philippines) residents as much as possible and to conduct site is scheduled to be developed along this request.
monitoring so that there is no problem with ・DPWH has two monitoring systems; 1) internal monitoring and 2) external
livelihoods and infrastructure services after monitoring, for resettlement monitoring.
resettlement. ・1) Internal monitoring mainly focuses on monitoring during the land acquisition
and resettlement, such as the progress of compensation payment. On the other
hand, in 2) external monitoring, independent external organization monitors the
progress of livelihood restoration assistance measures and restoration status after
resettlement, the satisfaction of project affected residents, and the presence or
absence of complaints by focusing on implementation of appropriate resettlement,
and make recommendations to DPWH. It is confirmed that DPWH will make
necessary improvements based on the recommendations if any. It was confirmed
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that external monitoring is under preparation in accordance with implementation


of the livelihood restoration program.
11 Pasig-Marikina River 4 As the current treatment of wastes including ・The project proponent explained that factory wastewater was treated before
Channel Improvement wastewater and hazardous substances are not always discharging to the drainage system which flows to Pasig-Marikina River.
Project (Phase 3) in a desirable condition, JICA should identify the ・In this project, in addition to conducting additional surveys on bottom sediment
(Philippines) impacts of these on the rivers to be maintained in the quality at the D/D stage, JICA agreed with the project proponent to carry out
project. monitoring on dredged soil, soil improved by pre-mixing treatment and river
water quality during the construction period.
・Monitoring of water quality is carried out, and no particular problem has been
identified.
11 Pasig-Marikina River 5 As for “Soil and groundwater contamination”, there ・A portion of the dredged soil is packed in pollutant confining bags and used for
Channel Improvement is a possibility that hazardous substances may be the embankment of this project. In addition, JICA confirmed that the project plans
Project (Phase 3) mixed in the soil. Therefore, JICA should confirm to use other dredged soil for landfilling after improvement by mixing with
(Philippines) that a facility or treatment method is in place to cements or lime stones and containing hazardous substances.
prevent soil and groundwater contamination, and if ・Moreover, it was agreed to conduct a detailed investigation and confirmation at

Feburary 2020
necessary, consider strengthening mitigation the D/D stage, to inspect the dredged soil before dredging and after treatment by
measures for the surrounding environment. the contractor and take additional measures as necessary, and to monitor the
groundwater quality of the landfill site.
・ Contamination of the dredged soil has not been confirmed.
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Project Title Advice to JICA JICA’s Confirmation Result at the Implementation Stage
No. Number
11 Pasig-Marikina River 14 On issues related to flood control of the entire ・ JICA requested the project proponent on the given advise and confirmed that
Channel Improvement watershed and this project, JICA should make sure the FMC was established as planned.
Project (Phase 3) that Flood Mitigation Committee (FMC) cooperates
(Philippines) with LIAC (Local Inter Agency Committee) to
tackle the issues.
12 New Bohol Airport 20 The tree planting plan needs to clearly mention the Both two planted species were confirmed as native species in Bohol. One species
Construction and use of primitive species and native species, and was a transplanted native species which was grown at the airport construction site,
Sustainable exclude non-native species, etc. as much as possible. and another species is a tree which is different species but in the same genus which
Environment In addition, JICA should consider appropriateness of was from the same island and outside the airport construction site. There is no
Protection Project the tree planting plan as the mitigation measures for non-native species planted.
(Philippines) flora and fauna and separately describe the
mitigation measures.
14 Mandimba-Lichinga 1 Confirm the mechanism to keep in close contact During the project appraisal, JICA confirmed the regular donor meeting is to be
Road Upgrading with AfDB and ensure consistency for the project. held every six months including ANE to communicate and coordinate with AfDB
Project (Mozambique) on the project.
At the project implementation stage, JICA confirmed that the project proponent
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had a record of meetings with AfDB.


14 Mandimba-Lichinga 7 As watering during the dry season is required at least During the project appraisal, JICA requested ANE to prepare the instruction
Road Upgrading three times a day as a dust control measure during manuals for effective dust control and to implement the dust control measure,
Project (Mozambique) the construction stage, confirm that the project pays namely watering at least three times a day for the dry season by prioritizing the
attention to consideration for affected areas such as affected areas.
providing instruction manuals for dust control at the At the construction stage, it was confirmed that waterings were conducted daily at
site to ensure the effective coverage. major work camps, gravel mining areas, sub-work camps, villages, and detour
areas, etc.
14 Mandimba-Lichinga 9 Confirm the impact on the water quality and take Regarding surface water, JICA confirmed the drainage ditch was installed along
Road Upgrading necessary measures during construction and the roadside in accordance with the ESIA, clogging (by soil or garbage) of the
Project (Mozambique) operation stages. drainage ditch was checked, and monitoring was conducted visually on turbidity
of river water near the construction site. No significant adverse impact has been
reported.
14 Mandimba-Lichinga 12 Confirm that there is no problem with population Measures against the impact of population inflow (Human Immunodeficiency
Road Upgrading inflow due to the improved convenience of the Virus/Acquired Immuno-Deficiency Syndrome: HIV/AIDS prevention program,

Feburary 2020
Project (Mozambique) project road. etc.) during the construction stage is included in the EMP and implemented
accordingly. During the operation stage, large-scale population inflow near the
project area due to the improved convenience by the project road is not expected,
and the study result mentioned that there is no particular problem anticipated.
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Project Title Advice to JICA JICA’s Confirmation Result at the Implementation Stage
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However, JICA requested ANE and the province government to implement the
appropriate measure if any problem occurs.
14 Mandimba-Lichinga 17 Confirm the specific expertise and the number of During the project appraisal, JICA confirmed with ANE that the environmental
Road Upgrading environmental and social specialists who will be monitoring will be supervised collectively by the Environmental Officer and
Project (Mozambique) engaged in the implementation of the environmental Social Officer of the Project Management Unit (PMU), and the Environmental
monitoring plan and the Environmental Monitoring Officer of the consultant and contractor(s). For EMU, 1 person in charge of
Unit (EMU). environmental and social considerations was selected from ANE, 1 person
selected from the consultant for safety management as well as environmental and
social considerations, and 5 persons who are social specialist, anthropologist,
coordinator, and manager are selected from the contractor.
14 Mandimba-Lichinga 18 Confirm the capacity building plan for the At the time of the project appraisal, JICA confirmed that there is no problem with
Road Upgrading environmental and social specialists in charge of the language skills of the staff involved in monitoring, and the capacity of the
Project (Mozambique) monitoring and its feasibility, since it is essential to project proponent staff is being improved due to technology transfer from the
improve the language and technical skills of the staff consultant and contractor(s). JICA also confirmed with ANE that the equivalent
involved in monitoring. level of staff will be hired in the future.
As it is confirmed at the implementation stage, the consultant hired with Japanese
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ODA loan provides technical support to the project proponent on environmental


and social monitoring.

20 San Miguel Bypass 10 As the role of traffic management plan is important The need for a traffic management plan, such as introduction of a car inspection
Construction Project as well as EMP and EMoP, JICA should propose the system that prevents unmaintained vehicles from traveling, traffic education (no
(El Salvador) necessity of traffic management plan in particular, horns unnecessarily), has been added to the “1.4 Recommendation” of the JICA
including introduction of a car inspection system that study report. In addition, JICA proposed the project proponent to prepare a traffic
prevents unmaintained vehicles from traveling. management plan for this project at the time of the project appraisal and
confirmed the project proponent’s intention to continue the traffic education
including speed control and moderate horn uses.
At the implementation stage, JICA confirmed with the project proponent that the
traffic management plan is prepared including installment of traffic lights in
accordance with the Central American Economic General Convention Permanent
Office (SIECA) standard; implementation of traffic safety training and campaigns
for nearby residents and students; limiting the traveling speed to 40 km/h;

Feburary 2020
preparation of bicycle and pedestrian lanes; and installation of bus stop spaces
along roads.
22 Bortnychi Sewage 4 Since GHG emission is expected to increase after the ・ As the energy sector accounts for 69 % of GHG emissions in Ukraine, GHG
Treatment Plant operation of this project, JICA should request the emission reduction is largely owed by the energy sector initiatives. In addition,
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Modernization Project project proponent to take measures against global when the method of accumulating sludge in the current sludge disposal site is used
(Ukraine) warming. as a baseline, the amount of GHG emissions will increase after commencement of
operation. However, it is confirmed that in comparison to the originally planned
French-type sludge incinerator, the Japanese-style sludge incinerator is expected
to reduce GHG more because of its higher efficiency (e.g. heat source using steam
and shared power source. etc.)
・ Based on the above effort, JICA requested the project proponent to reduce
GHG emission as much as possible during the project implementation.
・ Construction has not been started at this point, however, regarding sludge
incinerators that are expected to be introduced in this project, it is being
considered to introduce equipment that complies with EU environmental
standards.
24 North-South 4 As a result of monitoring by the external monitoring It was agreed with ADB and the project proponent that the monitoring results by
Expressway agency, when it is considered that the measures the external monitoring agency will be reported not only to ADB but also to JICA
Construction Project taken are insufficient or a further action is necessary, through Vietnam Expressway Corporation (VEC), the project proponent.
(Ben Luc - Long JICA and ADB also actively check the information JICA has also obtained and confirmed the external monitoring report.
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Thanh Section) (Viet provided via monitoring. It should be confirmed


Nam) with the project proponent that the results and
conclusion will not be left to the external monitoring
agency alone.
24 North-South 6 It is desirable to ensure in writing that the final JICA confirmed with the project proponent that the land compensation rate is
Expressway decision on the land compensation rate will be based determined based on the replacement cost; and if the land price goes up
Construction Project on the market price-based replacement cost; if the significantly, the project proponent will carry out the replacement cost survey
(Ben Luc - Long land price rises, it should be reflected; and the land again and the survey result will be reflected in the compensation rate. In addition,
Thanh Section) (Viet compensation will be provided to the land owner although it is clearly stated in the resettlement plan that compensation will be paid
Nam) before actual land acquisition. before the land acquisition, JICA confirmed with the project proponent again on
these matters.
Regarding the validity of the replacement cost survey, JICA confirmed the
replacement cost survey results and the due diligence report attached to the final
RAP of each district.
26 Mumbai Metro Line 3 8 In the pre-implementation stage, JICA should review At the time of the project appraisal, JICA agreed with the project proponent to

Feburary 2020
Project (India) the implementation plan for stakeholder consultation take action based on the given advice. The land acquisition process has not been
to be held after project affected residents have been completed, and the project proponent is continuing to discuss with the project
finalized. affected residents based on the stakeholder consultation implementation plan
which was confirmed by JICA.
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JICA has confirmed that stakeholder consultation has been conducted after the
project affected residents have been finalized.
26 Mumbai Metro Line 3 15 Since Section 2.10 of the SIA report states that "the At the time of the project appraisal in 2012, 52 project affected households did not
Project (India) household survey was not completely done due to cooperate in the survey. However, it has decreased to 26 households in August
frequent protests and non-cooperation", JICA should 2017. Among these 26 households, 13 households applied to the Complaint
confirm the number of households that have not Handling Committee and 5 households (3 residences and 2 commercials) were
been surveyed directly at the time of environmental recognized eligible.
review. More specifically, JICA should confirm Land acquisition and resettlement are ongoing and not yet completed. JICA will
whether the households who were opposing when continue to monitor the situation through project supervision.
the SIA was prepared are surveyed and whether they
express their support for the project.
26 Mumbai Metro Line 3 17 Please confirm the effectiveness of vocational In the Mumbai Urban Transport Plan (2005), vocational training and placement
Project (India) training for scheduled castes and scheduled tribes for low-income people, including the poor, scheduled castes, and scheduled tribes,
and to what extent they contributed to the new have been conducted, and the total of 1,571 people have obtained new jobs. Out of
employment opportunities based on experiences of these 1,571 people, 842 people have gained jobs through new skills training (e.g.
other projects. bag making, sewing techniques, food processing, etc.). This livelihood restoration
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program is also applied to this project.


The project proponent hires NGOs to support implementation of a livelihood
restoration program, and additionally hires an external monitoring agency to
monitor the livelihood restoration status.
According to the monitoring results, currently, the company has been selected to
carry out vocational training as per the micro plan, and the effectiveness will be
examined after implementation of the livelihood restoration program. The micro
plan is created based on the needs of each PAP.

29 Rengali Irrigation 6 As for the Wildlife Management Plans prepared by The cost of Rs. 268.5 million, which is required for the Wildlife Management
Project (Phase 2) the Forest Department, JICA should confirm its Plan, has already been deposited by the project proponent to the Forest
(India) progress, cost and responsibilities. Department. According to the Wildlife Management Plan, the Elephant Friendly
Ramps (EFRs) should be constructed at 28 locations in the left bank area, and all
of which have been constructed. In addition, 2 Elephant Passages are planned, and
1 passage is already constructed. The remaining 1 is scheduled to be built by the

Feburary 2020
project proponent. The constructed EFR and Elephant Passages will be maintained
by the Forest Department.
According to the monitoring results, the Wildlife Management Plan is currently
updated for Phase 2, and regular monitoring of elephants is being carried out in
Project Advice

JICA Study for Review of JICA Guidelines for Environmental and Social Considerations
Final Report
Project Title Advice to JICA JICA’s Confirmation Result at the Implementation Stage
No. Number
the elephant corridor.
31 Ahmedabad Metro 1 Ensure that the additional water demand has no During the operation stage, water use for vehicle cleaning is mainly expected at
Project (I) (India) major impact on other water uses and the the depot; however, 97% of water used for vehicle cleaning is recycled water, and
environment. JICA confirmed with the project proponent that there will not be a major impact
on other water use and environment.
In addition, at the implementation stage, it has been confirmed with the project
proponent that water supply for drinking water at stations and depots has already
been approved based on the Gujarat Groundwater Sustainable Use Plan, and it
will be taken from underground.
35 Olkaria V Geothermal 10 As for pipelines and roads planned in the project The followings are added in "Section 7. Animals and Ecosystems" in “Chapter 11
Power Development area including Hell’s Gate National Park, JICA Mitigation Measures and Costs for Implementing Mitigation Measures" under
Project (Kenya) should add the followings in the F/R of the JICA Part II, F/R.
Study: "It is desirable to implement the following mitigation measures:
(1) to study the movement of animals before • Keep enough distance between transmission lines so that birds are not killed by
construction starts; and an electric shock.
(2) to implement the mitigation measures as such ・ When installing bumps on roads in zones where wildlife passes, consider
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as changing the pipe alignment and installing locations where wildlife movement is expected, and install them at appropriate
speed bumps based on the study results. locations in consultation with KWS before construction begins"

As JICA confirmed at the implementation stage, speed bumps have been installed.
The steam collection pipes are designed camouflage of the natural environment.
The project proponent cooperated with the KWS to investigate the animal's
moving and the bird's flight route, and the results were shared with the consultant
and were reflected in the design.
38 The Project for 14 Since the draft RAP (p.31) discusses only the water As per the advice, other infrastructure development plans were added in the F/R
Construction of Nile supply plan of Tokiman West Lukata Moroyok for of the JICA Study, and JICA requested the project proponent to follow the plan
River Bridge (South the infrastructure development in the relocation site, accordingly.
Sudan) it should describe other infrastructure development The current progress after the JICA study could not be confirmed since the project
plans as much as possible. has been suspended due to the security reason.
38 The Project for 15 In the right column of the Employment Opportunity Additional description was added in the F/R of the JICA Study as per the advice,
Construction of Nile for PAPs in Table 8-1 Compensation Matrix of the and JICA requested the project proponent to follow the Compensation Matrix

Feburary 2020
River Bridge (South draft RAP, add “(Farmer, fisherman, brick accordingly.
Sudan) manufacturer and anybody whose livelihoods are The latest situation after the JICA study could not be confirmed since the project
affected by the project)”. has been suspended due to the security reason.
39 The Project for the 9 Generally, it is observed invasive alien species JICA confirmed that ballast water issue is not covered in the master plan since the
Project Advice

JICA Study for Review of JICA Guidelines for Environmental and Social Considerations
Final Report
Project Title Advice to JICA JICA’s Confirmation Result at the Implementation Stage
No. Number
Study on threaten coastal ecosystems through ballast water international legislation on ballast water as specified by IMO will be applied to all
Strengthening and are breeding for a long time in many countries. ships including dredgers.
Competitiveness and Therefore, JICA should 1) describe in the report an
Development of example of adverse impacts on ecosystems due to
Sihanoukville Port the invasion of alien species into the bay by dumping
(Cambodia) ballast water, and 2) include examination of proper
ballast water management to avoid alien species in
the draft TOR of the EIA to be conducted during the
F/S.
Source: Prepared based on the survey item sheets of individual projects
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CHAPTER 3 CHANGES AND TRENDS OF EXTERNAL ENVIRONMENT

Chapter 3 summarizes the survey results on changes in the environment surrounding JICA GL in
line with the survey items mentioned in Chapter 1.

3.1 Government Policies and International Aid

3.1.1 Development Cooperation Charter

In response to (1) diversification, complication and broadening of development issues the ODA
faces, (2) increasing role of non-ODA funds and activities for developing countries, and (3)
globalization, the ODA Charter (Cabinet Decision of 1992, revised in 2003) was revised in February
2015 as the Development Cooperation Charter. The points of the Development Cooperation Charter
are outlined in the table below. Responding to the diversification, complication and broadening of
the development issues, the major approach of the Charter is to strengthen collaboration with public-
private partnerships, international organizations, MDBs, and emerging countries.

As a principle of implementation, the Charter states that, in order to ensure appropriateness, it is


necessary to pay full attention to the various environmental impacts and climate change measures
associated with the developments, and to carry out the development cooperations with due
consideration to the environment. The Charter also states that the development co-operation shall
be carried out with due attention to social impacts and with participation of diverse participants at
all situations, from the view point of correcting disparities as well as considering socially vulnerable
people such as children, persons with disabilities, elderly people, ethnic minorities and indigenous
people.

Table 3-1 Outline of Development Cooperation Charter


Items Overview
1. Philosophy
(1) Objectives  Japan will promote development cooperation in order to contribute more
of proactively to the peace, stability and prosperity of the international community.
Development  Such cooperation will also lead to ensuring Japan’s national interests such as
Cooperation maintaining its peace and security, achieving further prosperity, realizing an
international environment that provides stability, transparency and predictability,
and maintaining and protecting an international order based on universal values.
 ODA, as the core of various activities that contribute to development, will serve
as a catalyst for mobilizing a wide range of resources in cooperation with various
funds and actors and, by extension, as an engine for various activities aimed at
securing peace, stability and prosperity of the international community.
(2) Basic A. Contributing to peace and prosperity through cooperation for non-military purposes
policies - The contribution to peace and prosperity of the world through non-military
cooperation is highly regarded as embodying our way as a peaceful nation.
- Japan will continue to uphold this policy and comply with the principle of
avoiding any use of development cooperation for military purposes or for
aggravation of international conflicts, in proactively contributing to securing
peace, stability and prosperity of the international community.

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Items Overview
B. Promoting human security
- Human security is the guiding principle that lies at the foundation of Japan's
development cooperation
- Japan will thus focus its development cooperation on vulnerable individuals and
provide cooperation for their protection and capacity building so as to realize
human security.
- Japan will also proactively contribute to promoting basic human rights, including
women's rights.

C. Cooperation aimed at self-reliant development through assistance for self-help


efforts as well as dialogue and collaboration based on Japan’s experience and expertise
- Japan will continue to provide cooperation aimed at developing countries' self-
reliant development by emphasizing their own initiatives and self-help efforts.
- Japan will attach importance to building the foundations of self-help efforts and
self-reliant development such as human resources, socio-economic infrastructure,
regulations and institutions.
- It will also go beyond waiting for requests from partner countries, we also
emphasize dialogue and collaboration with other countries, including proactively
presenting proposals from Japan.
2. Priority policies
(1)Priority A. "Quality growth" and poverty eradication through such growth
issues − As regards to the fragile states, Japan provides both assistance from a humanitarian
point of view and assistance designed to set the development process in motion and
overcome vulnerability.
− To resolve the poverty issue in a sustainable manner, it is essential to achieve
economic growth through human resources development, infrastructure
development and establishment of regulations and institutions as well as the growth
of the private sector.
− Economic growth must be “quality growth” (inclusive, sustainable, resilient) and
supports it by utilizing Japan's experience, expertise and technology.
− From this perspective, Japan will secure the foundation and driving force of
economic growth and will support for promoting human-centered development
that promotes basic human life.

B. Sharing universal values and realizing a peaceful and secure society


− Stable development through "quality growth" will not be achieved unless the rights
of individuals are guaranteed, people can engage in economic and social activities
with a sense of safety, and the society is managed equitably and stably.
− With a view to solidifying the foundations for such development, Japan will
provide assistance so as to share universal value and support for the realization of
a peaceful, stable, and safe society.
− Sharing Universal Values: the establishment of the rule of law, the realization of
good governance, the promotion and consolidation of democratization, and respect
for basic human rights including women's rights.
− Peaceful, stable and secure society: peacebuilding, emergency humanitarian
assistance (disaster relief, etc.), response to threats to stability and security
(maritime security, terrorism, security maintenance, international public goods,
etc.)

C. Building a sustainable and resilient international community through efforts to


address global challenges
− The global challenges cannot be dealt with by a single country. Taking full account
of the international development goals such as the Millennium Development Goals
(MDGs) and the post-2015 development agenda, Japan will seek to contribute to

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Items Overview
building a sustainable and resilient international community.

(2) Priority - Japan will implement strategic, effective and agile cooperation according to the
policy issues needs and characteristics of each region of the world (Association of Southeast
by region Asian Nations:ASEAN, South Asia, Central Asia and Caucasus, Africa, Middle
East, Central and Eastern Europe, Central and South America, Oceania and
Caribbean).
- Attention will be paid to the increasing relevance of recent developments moving
toward regional integration, regional level efforts, greater-area development, and
strengthening of inter-regional connectivity.
- Despite progress in development, some countries are laden with challenges that
hamper sustained economic growth, and small island countries and others are
faced with special vulnerabilities despite having attained a certain level of per
capita income. Japan will make necessary cooperation in accordance with the
actual development needs and capacity to curry the burden.
3. Implementation
(1) A. Principles for effective and efficient development cooperation
Implementation (a) A more strategic approach
principles - Formulate development cooperation policy and set goals based on foreign policy.
- Enhance synergy by coordinating ODA with non-ODA funding and cooperation.
- Conduct evaluation at policy and project level. Appropriate feedback on the
outcome of the policy making process.
(b) Cooperation that takes advantage of Japan's strengths
- Actively introduce proposals from the private sector etc. In addition to hardware
aspects such as infrastructure construction, it will also address the non-physical
aspects that encompass developing systems for operating and maintaining such
infrastructure as well as human resources development, system and institution
building
(c) Proactive contribution to international discussions
B. Principles for securing the appropriateness of development cooperation
(a) Situation regarding consolidation of democratization, the rule of law and the
protection of basic human rights
(b) Avoidance of any use of development cooperation for military purposes or for
aggravation of international conflicts
− Japan will avoid any use of development cooperation for military purposes or for
aggravation of international conflicts. In case the armed forces or members of the
armed forces in recipient countries are involved in development cooperation for
non-military purposes such as public welfare or disaster-relief purposes, such cases
will be considered on a case-by-case basis in light of their substantive relevance.
(c) Situation regarding military expenditures, development and production of weapons
of mass destruction and missiles, export and import of arms, etc.
(d) Impact of development on the environment and climate change
(e) Ensuring equity and consideration to the socially vulnerable
(f) Promoting women’s participation
(g) Preventing fraud and corruption
(h) Security and safety of development cooperation personnel

(2) A. Improvement of the implementation architecture of the government and the


Implementation implementing agencies
arrangements
B. Strengthening partnerships
(a) Public-private partnerships and partnerships with local governments
- The government will promote development cooperation through public-private
partnerships and partnerships with local governments utilizing the resources of the

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Items Overview
private sector and local governments and promoting private-led growth, in order
to support economic development of developing countries more vigorously and
effectively and to enable such development to lead to robust growth of the
Japanese economy as well.
- In promoting public-private partnerships, Japan’s development cooperation will
seek to serve as a catalyst for expanding economic activities, while utilizing
excellent technology and expertise, and ample funds of the private sector for
addressing the challenges faced by developing countries.
- Japan will strengthen collaboration with companies including SMEs, local
governments, universities and research institutes.
(b) Coordination in emergency humanitarian assistance and international peace
cooperation
− Japan will continue to promote coordination with international peace cooperation
activities such as international organizations and NGOs for emergency
humanitarian assistance and United Nations (UN) peacekeeping operations
(PKOs) to maximize their effective implementation.
(c) Partnerships with international, regional and sub-regional organizations
(d) Partnerships with donors, emerging countries and other actors
(e) Partnerships with the civil society

C. Strengthening the foundations for implementation


- In order for Japan's development cooperation to fulfil the required role of realizing
its philosophy and implementing its priority policies, the foundations for its
sustained implementation including financial and human resources must be
strengthened.
(a) Information disclosure and promoting understanding of the public and the
international community
(b) Promoting development education
(c) Developing human resources and solidifying the intellectual foundations for
development cooperation
Source: Unofficial English Translation of "Development Cooperation Charter Outline" from "Development Cooperation Charter Decision" by
JICA and JICA Study Team.
Created based on https://www.mofa.go.jp/mofaj/gaiko/oda/files/000072775.pdf (Ministry of Foreign Affairs , H 27.2 )

3.1.2 Promoting Quality Infrastructure Investment

The global demand for developing infrastructure, especially in emerging countries, is huge, and
rapid urbanization and economic growth are expected to further expand the market in the future.
Therefore, Japanese government promotes quality infrastructure investment to respond to the
overseas infrastructure demand and actively contribute to solutions for issues of international
society by utilizing the technology, knowledge and know-how in which Japan has an advantage and
collaboration between public and private sectors, which also contributes to realizing Japan's
economic growth. The contents of quality infrastructure investment promotion are summarized in
the following figure which is an excerpt from the document of the 43rd Management Council for
Infrastructure Strategy.

3. Promotion of Quality Infrastructure


(1) International standardization of quality infrastructure
 Lead the international standardization of quality infrastructure and contribute to sustainable
economic and social development, in order to secure “openness”, “transparency”, “economic

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efficiency” and “debt sustainability of borrowing countries” etc. in infrastructure development, in


accordance with the G20 principles for quality infrastructure investment and the Asia-Pacific
Economic Cooperation (APEC) guidebook
(2) Contribution to problem solving through the development of technologies and knowledge in
Japan, demonstrations, research and development, etc.
 Active use of technology, knowledge and know-how that Japan has an advantage in solving
problems in the international community and partner countries, regardless of developing or
developed countries
 Promote efforts based on the international framework, overseas expansion of technologies such as
decarbonization, energy saving, technology and know-how on disaster prevention/ water treatment
and waste disposal. Promote research and development of new technologies, and implementation of
those technologies.
 Improve price competitiveness by customizing Japan's strengths to meet the needs of the counterpart
country when socially implementing those technologies.
Overseas development of low carbon and decarbonizing technology
【Export expansion of renewable energy sector 【Realization of social implementation by
such as offshore wind】 customization】
· Create “Loan Insurance for Green Innovation” in ・ Reduce the initial cost by subsidizing JCM,
Nippon Export and Investment Insurance (NEXI), introduce high efficiency energy saving amorphous
which increase the coverage rate for renewable high efficiency transformer in Viet Nam
energy projects such as offshore wind power ・ Life cycle cost is demonstrated, and a
【Carbon Capture, Utilization and Storage (CCUS) distribution company adopts it as the procurement
/ carbon recycling】 standard
・ Realize CCUS / carbon recycling to treat ・ The core parts are made in Japan, and other
Carbon Dioxide (CO2) as parts production and assembly are localized to
resources, to capture it, and to achieve lower prices.
reuse it as fuel and materials ・ Technology transfer from Viet Nam to the third
for compatibility of energy country (e.g. Laos)
access improvement and
global warming measure
【Development of GHG emission reduction
technology】
・ Develop and expand Japan's superior
technologies, such as renewable energy and energy
Amorphous High Efficiency transformer
saving, through collaboration with developing
countries using the Joint Crediting Mechanism
(JCM) etc.
・ Use JCM in developing countries that do not
have regulations for recovery and destruction of
fluorocarbons, and support development of the
regulations and introduction of the destruction
facilities, etc.
Leading “Mainstreaming disaster risk Overseas development of water technology and
reduction”, and overseas development of know-how
disaster prevention technology
・ As Japan with a disaster prevention advanced In order to respond to the packaging of a wide
country that compiles the Sendai Framework range of fields such as integrated maintenance and
for Disaster Risk Reduction, it is highly operation for water supply and sewage treatment,
meaningful in terms of diplomacy to as well as integrated water resources management,

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incorporate the disaster risk reduction strengthen the function of the government as the
perspective into overseas infrastructure from control tower and promote integrated efforts in
the perspective of contributing to the Japan and overseas
strengthening of the world
・ Formulate catalogs that systematize Japan's
disaster risk reduction technology, know-how, Engineering,
Design Procurement & Operation
etc. Construction (EPC)
・ Strengthening follow-ups with officials of
recipient countries who participated in the Major Water Companies
(e.g. Veolia, SUEZ) Foreign
knowledge co-creation program in Japan Companies’
Emerging Country Overseas
Expanding Business
Monitoring
Accessible with Companies
Cloud mobiles, etc.
Data Service (e.g. Hyflux, Doosan) Business

Japanese Stakeholders

Manufacturers & Municipal


General Govt &
3L Water Level Meter Consultants Trading
Contractors
3L (Low Cost, Long Life, Localized) Water Level Meters and a water level Companies
information providing system with a cloud service which can be easily installed
in developing countries due to a lower cost

Source: Unofficial English Translation of Excerpt handout documents for the 43rd Management Council for Infrastructure Strategy "the
seventh follow up of infrastructure system export strategy" by JICA and JICA Study Team
http://www.kantei.go.jp/jp/singi/keikyou/dai43/siryou1.pdf
Figure 3-1 Promotion of Quality Infrastructure

3.1.3 G7 Ise-Shima Principles for Promoting Quality Infrastructure Investment

At the G7 Ise-Shima Summit held in 2016 to promote quality infrastructure investment advocated
by the Japanese government, "G7 Ise-Shima principle for promoting quality infrastructure
investment 1" as annex to the Summit Declaration was issued. The principle states “reaffirming the
crucial importance for stakeholders to work coherently to bridge the existing global demand-supply
gap of infrastructure investment by promoting quality infrastructure investment so as to promote
strong, sustainable and balanced growth and to enhance resilience in our society, we strive to align
our own infrastructure investment with the stated principles.” In principle 3, it states "quality
infrastructure investment must consider the social and environmental impacts of infrastructure
projects and duly address such impacts including by applying social and environmental safeguards
that are in line with international best practices as reflected in the most relevant standards including
those of existing MDBs," for addressing social and environmental impacts.

3.1.4 Trends of International Aid

The following is a brief summary of Sustainable Development Goals and the Paris Agreement as
international aid trends related to the environmental and social safeguard policy.

1
G7 Ise-Shima principle for promoting quality infrastructure investment https://www.mofa.go.jp/files/000196472.pdf

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Sustainable Development Goals (SDGs)

The Sustainable Development Goals (SDGs) were adopted as a successor to the Millennium
Development Goals (MDGs, 2001) at the UN Summit in September 2015. The SDGs are the
international goals from 2016 to 2030, described in the 2030 Agenda for Sustainable Development,
and are consist of 17 goals and 169 targets for a sustainable world. Its 5 major principles for
implementation include universality (taking actions by all countries including developed countries),
inclusiveness (reflecting the idea of human security “no one will be left behind”), participatory
approach (all stakeholders play their own roles), integrated approach (dealing with society, economy
and environment), and transparency and accountability (following-up regularly).

1) JICA's approach to SDGs


JICA formulated the policy for all the 17 goals and commiteed to contributing to achiving the SDGs.
JICA SDGs position paper 1 of September 12, 2016 states the three pillars of JICA's cooperation
toward achieving the SDGs: namely, (1) JICA has been working for realizing “human security” and
“quality growth” in order to contribute to peace, stability, and prosperity of the international
community. The SDGs accelerate and promote this Japan’s cooperation philosophy so that JICA
will proactively contribute to achieving the SDGs through its leadership; (2) JICA will play a key
role in achieving 10 goals [zero hunger, health, education, water/sanitation, energy, economic
growth, industry/infrastructure, sustainable cities, climate actions, forests/biodiversity] of the 17
SDGs making use of Japan’s own experience in socio-economic development of Japan and in
development cooperation for the international community; and (3) JICA will ensure the impact of
cooperation on the SDGs by utilizing Japan’s own knowledge, introducing innovations and
collaborating with local and international partners in order to accelerate the achievement of the
SDGs.

2) Efforts of WB and ADB to SDGs


The WB is also involved in the development of the SDGs, and its " Implementing the 2030 Agenda-
2018 Update " 2 states that the SDGs are consistent with WB Group's two goals: the end of poverty
and the promotion of shared prosperity. In particular, WB has advocated “the end of extreme poverty”
by 2030, and focuses on three areas: finance, data, and implementation support at the national level
to achieve the SDGs. 3 Within the "Implementing the 2030 Agenda - 2018 Update", in terms of the
finance, WB is utilizing internal resources, private resources, and developing tools to solve global
public goods issues (including epidemic disease, forced displacement, and climate change) in order
to increase the funding. For the data, WB is in charge of development, monitoring, and collecting
of data for reviewing the SDGs, and is in charge of creating the SDGs Atlas and reporting on 17

1
JICA’s Position Paper on SDGs: Toward Achieving Sustainable Development Goals (SDGs)
https://www.jica.go.jp/english/ir/bonds/c8h0vm0000awltie-att/bonds_01.pdf
2
“Implementing the 2030 Agenda - 2018 Update (WB, 2018)”,
http://pubdocs.worldbank.org/en/893311531748303554/2030Agenda-2018Update-July-19.pdf
3
Sustainable Development Goals (SDGs) and The 2030 Agenda, http://www.worldbank.org/en/programs/sdgs-2030-
agenda#1

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goals in the Inter-Agency Expert Group on the SDG Indicators. As for the implementation support
at the national level, in order to support an integrated analysis of the SDGs and the financial
framework, WB published "Trajectories for Sustainable Development Goals: Framework and
Country Applications " and supports development of policy framework and financial policy.

ADB has a website entitled "ADB and the SDGs." 1 In this website, it is stated that the operations
of ADB are linked with the SDGs from 2016 to improve the monitoring of contribution to the SDGs.
The site also includes efforts to identify investment projects for achieving the SDGs in the
counterpart countries, and to work with partners such as the UN system, MDBs, civil society, experts
and the private sector 2. In addition, in November 2017, "ADB's Transitional Results Framework,
2017 - 2020" along the SDGs were formulated.

The Paris Agreement

As the framework which promised that for the first time in history all of the country is working to
reduce greenhouse gas emissions, the Paris Agreement was adopted in UNFCCC 21st Conference
of Parties (COP21), which was held in Paris, France until December 13 from November 30, 2015.

Under the Paris Agreement, as a universal long-term reduction target, it stipulates that the
temperature rise from before the industrial revolution be suppressed to less than 2℃, and it mentions
the continuation of efforts for suppression to 1.5℃. It says “In order to achieve the long-term
temperature goal set out in Article 2, Parties aim to reach global peaking of greenhouse gas
emissions as soon as possible, recognizing that peaking will take longer for developing country
Parties, and to undertake rapid reductions thereafter in accordance with best available science, so as
to achieve a balance between anthropogenic emissions by sources and removals by sinks of
greenhouse gases in the second half of this century, on the basis of equity, and in the context of
sustainable development and efforts to eradicate poverty” 3 Under the Agreement, (1) all parties,
including major emitters and developing countries, will prepare Nationally Determined
Contributions (NDCs) and pursue domestic mitigation measures to achieve them and continue to
submit NDCs every five years with more ambitious targets; (2) all parties will also report regularly
on their activities and the information submitted will undergo a technical expert review, and based
on the review; (3) there will also be a global stocktake every five years to assess the collective
progress towards achieving the purpose of the Agreement.

Additionally, in October 2018, Intergovernmental Panel on Climate Change (IPCC) published a


special report on Global Warming of 1.5ºC. The report warns that human activities have caused
approximately 1.0°C of global warming above pre-industrial levels, and the warming is likely to
reach 1.5°C between 2030 and 2052 if the current trend continues. The report urges that rapid and

1
“ADB and the Sustainable Development Goals”, https://www.adb.org/site/sdg/main
2
“ADB and the Sustainable Development Goals”, https://www.adb.org/site/sdg/main
3
Paris Agreement Article 4 Paragraph 1, https://www.mofa.go.jp/mofaj/files/000197313.pdf

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far-reaching transitions in energy, land, urban and infrastructure (including transport and buildings),
and industrial systems (high confidence) is needed and global net human-induced CO2 emissions
must reach net zero at around 2050 to limit global warming to 1.5°C.

The Japanese government has expressed the "Actions for Cool Earth 2.0 (ACE 2.0)" including the
financial support of 1,300 billion yen for both the public and private sectors to climate change
assistance in developing countries in 2020.

In addition, "the long-term strategy under the Paris agreement" 1 has been approved by the Cabinet
of the Government of Japan on June 11, 2019. In this strategy, as a long-term vision, “proclaiming
a “decarbonized society” as the ultimate goal and aiming to accomplish it ambitiously as early as
possible in the second half of this century, Japan will boldly take measures towards the reduction of
GHGs emissions by 80% by 2050. To achieve this, according to the strategy, Japan will realize “a
virtuous cycle of environment and growth” towards the vision with business-led disruptive
innovation, start swift implementation of actions from now, and take actions for contribution to the
world and a bright society with hope for the future.

JICA issued a position paper on climate change 2 in September 2016. The position paper expresses
that JICA will further expand its climate change cooperation to developing countries based on the
Paris Agreement, and indicates that it will actively disseminate information domestically and
internationally.

3.2 Changes after the Enforcement of Current JICA GL

3.2.1 Responsibility of JICA

To consider JICA’s potential requirements for investment projects in the private sector, the
following sections describe the requirements for investment project of WB, ADB and IFC including
respective original paragraphs. Additionally, regulations and the necessary procedures in case of
non-compliance of the SGPs of the selected organizations are also summarized.

Responsibility for Investment Projects

WB: ESF is applicable to the Investment Project Financing, such as loans and guarantees provided
by International Bank for Reconstruction and Development (IBRD) and International Development
Association (IDA) (ESF, World Bank Environmental and Social Policy for Investment Project
Financing, Footnote 3, OP 10.00). WB Group’s private sector options are provided via Multilateral
Investment Guarantee Agency (MIGA) and IFC and not by WB. As for the ESF contents, the details

1
Outlines of Japan’s Long-term Strategy under the Paris Agreement https://www.env.go.jp/press/111914.pdf
2
“Position Paper on Climate Change (September 2016)”
https://www.jica.go.jp/activities/issues/climate/ku57pq00002cucus-att/position_paper_climate.pdf , “JICA Climate Change
Cooperation Strategy(September 2016)” https://www.jica.go.jp/english/our_work/climate_change/c8h0vm00005rzelb-
att/strategy_01.pdf

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are separately discussed in Section 3.3.1 Current Status and Trend of MDBs’ SGPs of this report.

This Environmental and Social Policy for Investment Project Financing sets out the mandatory
requirements of the Bank in relation to the projects it supports through Investment Project Financing.

Investment Project Financing is comprised of Bank Loans and Bank Gurantees, as defnied in OP
10.00.

Purpose, and Footnote 3,World Bank Environmental and Social Policy for

Investment Project Financing, WB ESF

ADB: SPS 2009 is applicable to all the ADB-financed and/or ADB-administered sovereign and non-
sovereign projects including loans, grants, investment and guarantees (para 48, SPS). For the
contents of ADB SPS, please refer to Section 3.3.1 Current Status and Trend of MDBs’ SGPs of this
report.

48. This safeguard policy statement applies to all ADB-financed and/or ADB-administered sovereign
and non-sovereign projects, and their components regardless of the source of financing, including
investment projects funded by a loan; and/or a grant; and/or other means, such as equity and/or
guarantees (hereafter broadly referred to as projects).

p. 15, Para 48, V. SAFEGUARD POLICY STATEMENT


A. Overarching Statement on ADB’s Commitment and Policy Principles
ADB SPS (2009)

IFC: IFC PS is applied to various projects including loans for the project, FI, investment in the
project company but which have the medium or high environmental and social risks or any
environmental and social impacts are identified (para3, Policy on Environmental and Social
Sustainability, 2012). As for of IFC PS, please refer to Section 3.3.1 Current Status and Trend of
MDBs’ SGPs of this report.

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3. Activities supported and financed by IFC include a wide range of investment and advisory products.
Investment products with longer tenor include: (i) direct lending to private sector companies (including
corporate and project finance); (ii) lending to various types of FIs as well as through funds and facilities;
(iii) minority equity stakes in companies, including in financial institutions; and (iv) guarantee
facilities, municipal finance, as well as investments managed by IFC’s Asset Management Company
or any other IFC subsidiary. Investment products with shorter tenor include short-term loans,
guarantees, and trade finance products, with maturities of up to three years. Proposed investments
that are determined to have moderate to high levels of environmental and/or social risk, or the
potential for adverse environmental and/or social impacts will be carried out in accordance with
the requirements of the Performance Standards.

para 3, IFC Policy on Environmental and Social Sustainability


(The bold font was added by JICA Study Team)

Regulations in Case of Non-Compliance

ADB: para 72 of SPS says that if the borrower/client fails to comply with legal agreements on
safeguard requirements and to reestablish compliance, ADB may exercise legal remedies that are
available under ADB legal agreements. However, the SPS does not differentiate requirements for
loan projects and for equity investment projects, and there is no separate requirement specifically
for equity investment projects.

C. Roles and Responsibilities

72. If a borrower/client fails to comply with legal agreements on safeguard requirements, including
those described in the safeguard plans and frameworks, ADB will seek corrective measures and
work with the borrower/client to bring it back into compliance. If the borrower/client fails to
reestablish compliance, then ADB may exercise legal remedies, including suspension,
cancellation, or acceleration of maturity, that are available under ADB legal agreements.
Before resorting to such measures, ADB uses other available means to rectify the situation
satisfactory to all parties to the legal agreements, including initiating dialogue with the parties
concerned to achieve compliance with legal agreements.

p. 26, ADB SPS (2009)


(The bold font was added by JICA Study Team)

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IFC: para 24 of Policy on Environmental and Social Sustainability states “if the client fails to
comply with its environmental and social commitments and to reestablish compliance, IFC will
exercise its rights and remedies, as appropriate”. However, it does not differentiate requirements for
loan projects and for equity investment projects, and there is no separate requirement specifically
for equity investment projects.

24. IFC’s agreements pertaining to the financing of clients’ activities include specific provisions
with which clients undertake to comply. These include complying with the applicable requirements
of the Performance Standards and specific conditions included in action plans, as well as relevant
provisions for environmental and social reporting, and supervision visits by IFC staff or
representatives, as appropriate. If the client fails to comply with its environmental and social
commitments as expressed in the legal agreements and associated documents, IFC will work with
the client to bring it back into compliance , and if the client fails to reestablish compliance, IFC will
exercise its rights and remedies, as appropriate.

Para 24, IFC Policy on Environmental and Social Sustainability

Additionally, IFC’s Access to Information Policy (AIP) (January 1, 2012) and ADB’s AIP
(September 2018) have no separate requirements and responsibilities specifically for equity
investment projects.

3.2.2 JICA’s New Assistance Program Started after the JICA GL Enforcement in 2010

After the current GL’s enforcement in 2010, there are some new assistance programs which are
started or to be started, namely private-sector investment finance, support for Japanese SMEs and
SDGs businesses, and projects funded by the Green Climate Fund (GCF). Since the private-sector
investment finance is included in the official development assistance loans, the GL are applied as
defined in Section 1.7 Covered Schemes of the GL. On the other hand, projects for promoting SMEs
and SDGs businesses and projects funded by the GCF are not included in the “covered schemes” in
the GL.

The outline of the private-sector investment finance and support for SMEs and SDGs businesses are
described briefly in the following table. The projects to be financed by the GCF are a newly added
scheme and there is no accepted project as of this report. Therefore, they are not included in the
following table.

Table 3-2 Outline of PSIF and Support for SMEs and SDG Businesses
1)
Scheme Objective 1) Description
PSIF Providing direct investment or loans to the Loan Amount/Percentage2): in principle, up
project with a large development impacts to 70% of the total project cost. Could be
financed by the private sector increased to 80% if it is justified (special
project characteristics will be considered).

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Scheme 1) Objective 1) Description


Investment Amount/Percentage2): in
principle, 50% or less than 50% of the capital
(in case of the company belongs to the
recipient country, 25% or below).
Additionally, JICA will not be the largest
investor. It is also possible to assist the
project via a fund.
Support Promotion Collection and analysis of basic Only for SMEs 3): Up to 8.5 million yen.
for SMEs Survey information related to the project (approx. In case of the distance areas which is other
and SDG 1 year) areas besides East Asia, Southeast Asia and
Businesses South Asia, the international airfare will be
upto 3 million yen, other direct expenses
upto 6.8 million yen.
Feasibility Feasibility survey on the technology, SMEs 4): up to 30 million yen. If shipping of
Survey products and know-how to be promoted the equipment (excluding small equipment)
and drafting the business model (approx. is required, could be increased to 50 million
several months to 1 year) yen.
SDG Business (large scale company only):
up to 8.5 million yen.
Verification Verifying the technology/products to be SMEs 5): up to 100 million yen/project. If it
Survey promoted and the business model. is to solve complicated issues or involves a
Preparing the draft business plan through large product or high technology, up to 150
promotion activities (approx. 1-3 years) million yen.
SDG Business (large scale company only) 6):
up to 50 million yen.
Source: Prepared by JICA Study Team based on the following information
1) Assistance Menu of Private Sector Investment Finance (Japanese only)
(https://www.jica.go.jp/priv_partner/activities/index.html)
2) FAQs for Private Sector Investment Finance (Japanese only)
(https://www.jica.go.jp/activities/schemes/finance_co/loan/faq.html)
3) Promotion Survey (Support for SMEs) (Japanese only)
(https://www.jica.go.jp/priv_partner/activities/smebmfs/index.html)
4) Feasibility Survey (Support for SDGs business) (Japanese only)
(https://www.jica.go.jp/priv_partner/activities/sdgsbmfs/index.html)
5) Verification Survey (Support for SMEs) (Japanese only)
(https://www.jica.go.jp/priv_partner/activities/smebvs/index.html)
6) Verification Survey (Support for SDGs business) (Japanese only)
(https://www.jica.go.jp/priv_partner/activities/sdgsbvs/index.html)

PSIF

PSIF covers 3 areas, namely infrastructure/acceleration of growth, SDG/poverty reduction and


climate change, and the accepted projects are listed in the following table. The agreements for 24
investment finance projects were signed between 2011 and December 2018 and ranges from small
scale non-infrastructure projects (e.g. human resource development for industries, microfinance,
coffee value chain, climate change related fund) to various infrastructure projects (e.g. industrial
estates, ports, a combined cycle power plant project). Environmental category of these project varies
from A to C and FI. The PSIF is subject to apply the JICA GL since it is a part of the ODA loans.

Table 3-3 PSIF Projects upto December 2018


Environmental
No. Signed Date Country Project
Category
1 September 2018 Brazil Agricultural Supply Chain Enhancement Project FI
2 July 2018 Bangladesh East-West Medical College Hospital Project C
3 May 2018 Viet Nam Coffee Value Chain Enhancement Project B
4 December 2017 Jordan Al-Muwaqqar Solar Energy Project B

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Environmental
No. Signed Date Country Project
Category
5 December 2017 Indonesia Renewable Energy and Infrastructure FI
Acceleration Facilities
6 August 2017 Myanmar Thilawa Special Economic Zone (Zone B Phase 1) A
Development Project (Private Sector Investment
Finance)
7 June 2017 Bangladesh Maheshkahali LNG Floating Storage Re- B
gasification Unit Terminal Activities Project
8 June 2017 Philippines Non-Revenue Water Improvement Project in the B
West Zone of Metro Manila
9 May 2017 Cambodia Sihanoukville Autonomous Port IPO B
10 May 2017 Bangladesh Sirajganj Combined Cycle Power Plant Project A
11 October 2016 Tanzania Off-Grid Solar Power Project C
12 September 2016 Mongolia Tsetsii Wind Farm Project B
13 September 2016 ASEAN countries Japan ASEAN Women Empowerment Fund C
and the other Asian (Investment project under the Private Sector
countries Investment Finance)
14 April 2016 Middle East and Middle East and North Africa Fund (Investment FI
North Africa project under the Private Sector Investment
countries and Finance)
region
15 May 2016 Asian Countries Leading Asia’s Private Infrastructure Fund FI
16 December 2015 Asian Countries Asia Climate Partners LP (Investment project FI
under the Private Sector Investment Finance)
17 August 2015 Viet Nam Rental Factory Development Project for SMEs B
(Loan Project under the Private Sector Investment
Finance)
18 June 2015 Cambodia Emergency Life Saving Center Development C
Project
19 November 2014 Latin American MGM Sustainable Energy Fund LP (Investment FI
Countries project under the Private Sector Investment
Finance)
20 April 2014 Myanmar Thilawa Special Economic Zone (Class A Area) A
Development Project (Private Sector Investment
Finance)
21 May 2014 Indonesia Industrial Human Resource Development Project C
22 January 2013 Viet Nam Rental Factory Development Project for SMEs B
23 May 2012 Pakistan Microfinance project in Pakistan (Investment C
project under the Private Sector Investment
Finance)
24 December 2011 Viet Nam Industrial Human Resources Development Project C
Source:Prepared by JICA Study Team based on the following document.
1. Private-Sector Investment Finance
(https://www.jica.go.jp/activities/schemes/finance_co/loan/resumption.html)

Support for SMEs and SDGs Businesses

Support for SMEs and SDGs Businesses consists of SME assistance for SMEs and SDGs business
for large enterprises. The SME support includes the promotion survey, feasibility survey and
verification survey. The SDGs business support includes the feasibility survey and verification
survey.

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Support for SME/SDGs Business (Support for SMEs)

Support for SMEs consists of 3 survey types, and the project duration varies from 3 months to 3
years. The budget also varies from JPY8.5 to 150 million. Operationally, the JICA GL are applied
to these projects except the promotion survey. Major project sectors are environment/energy, waste
management, water purification/treatment, vocational training/industrial promotion, welfare,
agriculture, public health/medical service, education, and disaster prevention/management. The
SME support projects accepted by JICA and its environmental category are described in Table 3-4.

(a) Promotion survey: Since the number of accepted projects in recent years is 17-26 projects
annually, only projects announced in FY2018 are summarized in the following table. However, since
this scheme is to collect the information and does not aim the feasibility study, operationally, the
JICA GL are not applicable for this scheme.

Table 3-4 Support for SME/SDGs Business (1) Promotion Survey (SME Support)
(Announced on 16th April 2018)
No. Country Proposing Enterprises Project Name
(representative)
1 Indonesia Hokkaido Poracon Survey on Introducing Porous Concrete Products for Prevention of
Co., Ltd. Damage to Infrastructure by Expansive Clays (SME Partnership
Promotion)
2 Philippines Zen Co., Ltd Survey on Introducing Concrete Repairing Material for Preventing
Japan Prolong Water Leakage in Philippine (SME Partnership Promotion)
Limited Company
3 Philippines Berg Earth co., Ltd Survey on Grafted Seedlings Business for High-Quality-Yield
Vegetables in Philippine (SME Partnership Promotion)
4 Cambodia West Management Survey on Distributing and Utilizing of Japanese Small Second-Hand
Co., Ltd. Construction Machineries Supporting Construction Infrastructure in
Cambodia (SME Partnership Promotion)
5 Viet Nam Grandsoul Research Survey on Improving the Quality of Cancer Care (SME Partnership
Institute for Promotion)
Immunology
6 Viet Nam Green Techno 21 Survey on Organic Lime Fertilizer Project utilizing Waste Eggshell in
Viet Nam(SME Partnership Promotion)
7 Viet Nam Kotobuki Kankyoh Survey on Water Treatment System of Lakes and Ponds in Viet
Kizai Co., Ltd. Nam(SME Partnership Promotion)
8 Myanmar Nakashima Special Basic survey on local development of special metal molds utilizing
Steel / Metalnics Co., high quality special steel (SME Partnership Promotion)
Ltd.
9 Mongolia Yamaguchi Sangyou Survey on Mongolian Leather Branding based on the RUSSETY
Co., Ltd. Tanning Method in Mongolia (SME Partnership Promotion)
10 Tanzania Studio Canbe Corp Survey on Effective Delivery of Bus Rapid Transit Service through
Mobile App in Tanzania (SME Partnership Promotion)
11 Zambia Alpha Kogyo K.K Survey on Bridge Repair Utilizing Epoxy Resin in Zambia (SME
Partnership Promotion)
12 Burkina Faso Koken Boring Survey on Groundwater Development of Dry area in Burkina Faso
Machine Co., Ltd. (SME Partnership Promotion)
13 Senegal Stella Environment Survey on the Effectiveness of Small-Scale Incinerator for the
Corporation Healthcare Wastes in the semi-decentralized in Senegal (SME
Partnership Promotion)
Source: Prepared by JICA Study Team based on the following information.
List of Accepted Projects under Support for Japanese SMEs Overseas Business Development FY2018 (1) – Promotion Surveys (16
April 2018): https://www.jica.go.jp/announce/notice/fs/ku57pq000027tajl-att/fs_180814_result.pdf
Additionally, accepted projects under Support for Japanese SMEs Overseas Business Development before FY2017 are available on
the below link – Promotion Surveys (SMEs):
https://www.jica.go.jp/priv_partner/activities/fs/index.html

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(b) Feasibility Survey for SME Support: Although the projects are not the cooperation assistance
applying the JICA GL, operationally the GL have been applied to the projects since the projects
include a feasibility survey. Since recently the number of the feasibility surveys is approx. 20-36
projects annually, only the projects announced in FY2018 are summarized in the following table.
Mostly the projects are classified as environmental category C.

Table 3-5 Support for SME/SDGs Business (2) Feasibility Survey (SME Support)
(Announced on 16th April 2018)
Proposing
Environmental
No. Country Enterprises Project Name
Category
(representative)
1 Indonesia Nakazato Feasibility Survey for Cleaning of Urban Water C
Construction Co., Supply Pipes to Improve Water Quality and Supply
Ltd. Capacity in Indonesia
2 Indonesia Ishibashi Co., Ltd. Feasibility Survey for Creating Supply Chain of C
Organic Wastes Recycling in Indonesia
3 Philippines Takara Co., Ltd. Feasibility Survey for increasing garlic production C
and producing processed black garlic for
improvement of livelihood in the Philippines
4 Thailand Mikiriken Feasibility Survey for Decolorization of Dyeing C
Industrial Co.,Ltd. Waste Water by Microorganism in Thailand
5 Thailand Nakamura Feasibility Survey for an Application of Multi- C
Shobokagaku Co., functional Fire Fighting Pump to Mitigate Forest Fire
Ltd. and Haze in Chiang Mai, Thailand
6 Cambodia Takii & Co.,Ltd Feasibility Survey for Quality Seed and Grafting C
Method for High Value-Added Vegetable Farming in
Cambodia
7 Laos Sanko Feasibility Survey for Durable Road Construction by B
Construction Co., Utilizing Precast Concrete in Laos
Ltd.
Okayama Concrete
Industry Co., Ltd.
8 Laos Negoro Sangyo Feasibility Survey for Producing Regenerated Raw C
Co.,Ltd Materials from Waste PET Bottles in Laos

9 Viet Nam Suzuken Kogyo Feasibility Survey for Reducing the Amount of C
Co.,Ltd Construction Waste by Safety and Efficient Sorting
and Separation System in Viet Nam
10 Viet Nam Nakashima Bussan Project survey on improving shrimp farming C
Co., Ltd. productivity through natural harmonized aquaculture
technology
11 Myanmar OKAMURA Co., Feasibility Survey for Advanced Johkasou C
Ltd. Introduction to Hospitals, Markets etc. in Poor South
Delta Area for Water Sanitation Improvement
12 Myanmar Harue Co., Ltd. Feasibility Survey for System Introduction on B
Collection, Transportation and Incineration of
Medical Waste for the Preparation of Private
Consignment in Yangon, Myanmar
13 Myanmar Merry Time Foods Feasibility Survey for Shrimp Hatchery Technologies B
Co., Ltd., in Myanmar
Higashimaru Co.,
Ltd.
14 Mexico Asada Corporation Feasibility Survey for the Reduction of Seashell B
Waste by High-performance Small Incinerator and
the Recycling of Incineration Residues for
Agriculture, Fisheries, Animal Husbandry in Mexico
15 Mexico Kuroda Industry Feasibility Survey for Recycling Technology for C
Co., Agricultural Film and Plastic in Mexico
Pantech Co.,
16 Nicaragua βace,Inc. Feasibility Survey for the Cacao Value Chain C

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Proposing
Environmental
No. Country Enterprises Project Name
Category
(representative)
Development and Value Addition in Nicaragua
17 Peru Lequios Soft Inc. Feasibility Survey for Disaster Prevention by C
Japanese Early Earthquake Warning System in Peru
18 Kenya Tomita Feasibility Survey for establishing a production site C
Technologies Ltd. of horticultural crops with hydroponics in Northern
Corrido in Kenya
Source: Prepared by JICA Study Team based on the following information.
List of Accepted Projects under Support for Japanese SMEs Overseas Business Development FY2018 (1) – Feasibility Surveys (16
April 2018): https://www.jica.go.jp/priv_partner/activities/smebmfs/index.html
Additionally, accepted projects under Support for Japanese SMEs Overseas Business Development before FY2017 are available on
the below link – Feasibility Surveys (SMEs):
https://www.jica.go.jp/priv_partner/activities/fs/index.html

(c) Verification Survey for SME Support: Although the project is not the cooperation assistance
applying the JICA GL, operationally the GL have been applied to the project since the project has a
possibility to have environmental and social impacts. Since recently the number of the verification
surveys is approx. 16-19 projects annually, the projects that the agreements were signed in the 1st
and 2nd quarters of FY2018 are summarized in the following table. The projects are classified as
environmental category C except 1 project.

Table 3-6 Support for SME/SDGs Business (3) Verification Survey (SME Support)
(Announced on 16th April 2018)
Proposing
Environmental
No. Country Enterprises Project Name
Category
(representative)
1 Viet Nam Naniwa Flower Verification Survey with the Private Sector for C
Auction Co., Ltd. Disseminating Japanese Technologies for Value Added
Cut Flower in Lam Dong Province, Viet Nam
2 Viet Nam J Files Co., Ltd. Verification Survey with the Private Sector for B
Disseminating Japanese Technologies for the Advanced
Waste Water Treatment System Suited for High BOD
3 Viet Nam Watakyu Seimoa Verification Survey with the Private Sector for C
Corporation. Disseminating Japanese Technologies for Linen Supply
for Improving Hygienic Environment in Public Hospitals
in Viet Nam
4 Viet Nam Fe System Work Verification Survey with the Private Sector for C
Corporation. Disseminating Japanese Technologies for Improving
Agricultural Processing and Product Development
Capacity through Inter-City Collaboration between
Asahikawa City and Quang Ninh Province in Viet Nam
5 Myanmar Lead Giken Verification Survey with the Private Sector for C
Disseminating Japanese Technologies for Electric Assist
Bicycle in Myanmar
6 Mongolia Toitu Co., Ltd. Verification Survey with the Private Sector for C
Disseminating Japanese Technologies for Introducing
Cardiotocography and Central Monitor System for
Improving Prenatal Care in Mongolia
7 India Uotani Co., Ltd. Verification Survey with the Private Sector for C
Disseminating Japanese Technologies for the
Improvement of Productivity and Quality of Sugarcane
through Sugarcane Harvester in India
8 Mexico Ocean Verification Survey with the Private Sector for C
Construction Co., Disseminating Japanese Technologies for Sustainable
Ltd Fishery with Using Shellnurse in Mexico
9 Mexico Kanepackage Verification Survey with the Private Sector for C
Co., Ltd. Disseminating Japanese Technologies for Promoting

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Proposing
Environmental
No. Country Enterprises Project Name
Category
(representative)
further development in Packaging Industry as a
Supporting Industry for Automobile Industry
10 Ecuador Astem Co., Ltd. Verification Survey with the Private Sector for C
Disseminating Japanese Technologies for Information
Infrastructure for Safety and Security of Persons with
Inadequate Access to TV Broadcasting
11 Morocco Eco-stage Verification Survey with the Private Sector for C
Engineering Co., Disseminating Japanese technologies for Recycling of
Ltd., Olive Mill Waste by use of Oil Temperature
Decompression Drying Machine
12 Kenya KJS Company Verification Survey with the Private Sector for C
Disseminating Japanese Technologies for Establishment
of e-Learning System for improvement in Quality of
Education in Kenya
13 South Africa Hayashi Soji Co., Verification Survey with the Private Sector for C
td. Disseminating Japanese Technologies for Preventing
Railway Track Accident
14 Tanzania Tsuji Plastics Inc. Verification Survey with the Private Sector for C
Disseminating Japanese Technologies for Improving
Night-time Road Safety through Application of Solar-
powered Active Road Studs in Tanzania
Senegal Teral Inc. Verification Survey with the Private Sector for C
Disseminating Japanese Technologies for Upgrading and
Expanding Small Water Supply Source with AC and DC
Powered Solar Pump Systems in Rural Area
Source: Prepared by JICA Study Team based on the following information.
1. List of Accepted Projects under Support for Japanese SMEs Overseas Business Development FY2018 (1) – Pilot Surveys (16 April
2018): https://www.jica.go.jp/announce/notice/teian/ku57pq000027tbez-att/teian_180814_result.pdf
2. Information Disclosure under new Guidelines: https://www.jica.go.jp/english/our_work/social_environmental/id/index.html
Additionally, accepted projects under Support for Japanese SMEs Overseas Business Development before FY2017 are available on
the below link –Pilot Surveys (SMEs):
3. Pilot Surveys (SMEs): https://www.jica.go.jp/priv_partner/activities/smebvs/index.html

Support for SME/SDGs Business (Support for SDG Business)

Support for SDG Business was a newly established scheme in July 2018 and so far no accepted
projects as of December 2018.Since projects might have a feasibility survey or environmental and
social impacts, operationally, the JICA GL are applied to the projects. The previous 2 support
programs, namely (1) Feasibility Survey for SDGs Business and (2) Collaboration Program with
the Private Sector for Disseminating Japanese Technology also applied the JICA GL operationally,
although they were not the cooperation assistance which were covered by the JICA GL. These two
previous support programs where the agreement were signed in the 1st and 2nd quarters of FY2018
are summarized in the following table. All the projects are classified as environmental category C.

Table 3-7 Previous Support Projects which are Classified as Support for SDGs
No. of
Proposing
Announcement Environmental SDGs to
No. Country Enterprises Project
Date Category be
(representative)
Achieved
Feasibility Survey for SDGs Business (Currently classified as SDGs Business)
1 8th April 2018 Indonesia Teijin Frontier Feasibility Survey for C 3
Co.,Ltd. , SDGs Business on
Mosquito Repellent
Clothing Production and
Sales to Prevent Dengue
Fever

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No. of
Proposing
Announcement Environmental SDGs to
No. Country Enterprises Project
Date Category be
(representative)
Achieved
2 8th April 2018 Myanmar Alps Feasibility Survey for C 10
Pharmaceutical SDGs Business on
lnd. co., Ltd. Senna Production and
Processing to Improve
the Income of Small-
Scale Farmers
3 8th April 2018 Myanmar Sompo Risk Feasibility Survey for C 1,13
Management & SDGs Business on
Health Care Development and
Inc. Dissemination of Loan-
Incidental Insurance
Products to Improve the
Access to Finance in
Rural Areas
4 8th April 2018 Bangladesh Ichiban Life Feasibility Survey for C 10
Corporation SDGs Business on
Molinga Production,
Processing and
Marketing to Improve
the Income of Farmers
5 8th April 2018 South Africa Remote Feasibility Survey for C 2,13
Sensing SDGs Business on
Technology Dissemination of
Center of Japan Agricultural Information
Services to Improve
Agricultural Productivity
by Using Satellite-Based
Data
6 8th April 2018 Burkina Fuji Oil Feasibility Survey for C 2,5
Faso Holdings Inc. SDGs Business on
Establishing Soybean
Food Value Chain to
Improve Nutrition and
Increase Women's
Income
Collaboration Program with the Private Sector for Disseminating Japanese Technology
7 14th May Indonesia OPTiM Collaboration Program C -
2018 Corporation with the Private Sector
for Disseminating
Japanese Technology for
Remote Work Assisting
Service
8 14th May Cambodia Nichireki Collaboration Program C -
2018 Co.,Ltd. with the Private Sector
for Disseminating
Japanese Technology for
In-place Base Course
Stabilization System for
Solid Pavement
9 14th May Viet Nam Michinori Collaboration Program C -
2018 Holdings, Inc. with the Private Sector
for Disseminating
Japanese Technology for
Bus Management and
Operation Know-how
10 14th May Nepal Nikken Collaboration Program C -
2018 Sohonsha with the Private Sector
Corporation for Disseminating
Japanese Technology for
Environment-friendly
Slope Restoration with
Soil Algae

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No. of
Proposing
Announcement Environmental SDGs to
No. Country Enterprises Project
Date Category be
(representative)
Achieved
11 14th May Kenya Kaneka Collaboration Program C -
2018 Corporation with the Private Sector
for Disseminating
Japanese Technology for
PHBH Compound Based
Bio-degradable Plastic
Bags
12 14th May Kenya Wellthy Collaboration Program C -
2018 Corporation with the Private Sector
for Disseminating
Japanese Technology for
Treatment of Seasonally
Varying Highly Turbid
Water
Source: Prepared by JICA Study Team based on the following information.
1.Feasibility Survey for SDGs Business:
https://www.jica.go.jp/announce/notice/bop/ku57pq000027nsw1-att/result_01_20180406.pdf
2. Project for promotion of private technology for social and economic development of development countries
https://www.jica.go.jp/announce/notice/kaihatsu/ku57pq000028izy0-att/result_20180514.pdf

Entrustment by the Green Climate Fund

In 2017, JICA was accredited as an implementing entity of GCF and is implementing GCF funded
projects as per para 3, Chapter 13, the Act of the Incorporated Administrative Agency - Japan
International Cooperation Agency. Currently, some proposals to be submitted to GCF are being
prepared but are not yet accepted. It is expected that the JICA GL will be applied to the entrusted
projects by GCF.

3.3 Summary of MDBs’ SGPs

3.3.1 Current Status and Trend of MDBs’ SGPs

Overview of MDBs’ SGPs

Structures of SGPs, Guidance Notes (GN) and relevant documents of the WB, ADB and IFC are
summarized below. In addition to the documents listed in the table, these MDBs also prepare and
publish safeguards-related evaluation reports, case studies and reports on specific topics.

Table 3-8 Summary of MDBs’ SGPs


Document WB ADB IFC
Policy ESF (2016): The ESF sets out SPS (2009): The SPS describes Sustainability Framework
the WB’s commitment to common objectives of ADB’s (Updated in 2012): The
sustainable development safeguards, lays out policy Framework articulates IFC's
through a Bank Policy and 10 principles, and outlines the strategic commitment to
ESSs. The ESF consists of i) a delivery process for ADB’s sustainable development and is
Vision for Sustainable SGP. Appendix 1 to 4 articulate an integral part of approaches
Development; ii) WB specific safeguard requirements for risk management. The
Environmental and Social for the borrower/ client, which Framework consists of i) the
Policy for Investment Project are: Policy on Environmental and
Financing (the mandatory - 1. Environment Social Sustainability; ii) the PS;
requirements that apply to the and iii) the AIP.
Bank; and iii) ESSs (the - 2. Involuntary Resettlement
mandatory requirements for the The PSs are:

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Document WB ADB IFC


borrowers and the projects). - 3. Indigenous Peoples - PS1: Assessment and
The ESF was approved in 2016 Management of
and took effect in 2018.
- 4. Special Requirements for Environmental and Social
Different Finance Modalities Risks and Impacts
The ESSs are: - PS2: Labor and Working
- ESS1: Assessment and Operations Manual Bank Conditions
Management of Policies (BP) Safeguard Policy
Environmental and Social Statement (for staff use)(2013): - PS 3: Resource Efficiency
Risks and Impacts These policies were prepared and Pollution Prevention
- ESS2: Labor and Working for use by ADB staff. - PS4: Community Health,
Conditions Safety, and Security
- ESS3: Resource Efficiency - PS5: Land Acquisition and
and Pollution Prevention and Involuntary Resettlement
Management
- PS6: Biodiversity
- ESS4: Community Health Conservation and Sustainable
and Safety Management of Living
Natural Resources
- ESS5: Land Acquisition,
Restrictions on Land Use and - PS7: Indigenous Peoples
Involuntary Resettlement
- PS8: Cultural Heritage
- ESS6: Biodiversity
Conservation and Sustainable AIP articulates IFC’s
Management of Living commitment to transparency.
Natural Resources
- ESS7: Indigenous
Peoples/Sub-Saharan African
Historically Underserved
Traditional Local
Communities
- ESS8: Cultural Heritage
- ESS9: Financial
Intermediaries
- ESS10: Stakeholder
Engagement and Information
Disclosure
Guidance GN for Borrowers (2018): The - GN (2012): Guidance Note is
Note (GN) GN provide guidance for the prepared for each PS to offer
borrower on the application of helpful guidance on the PS
each ESS. requirements. GN 6:
Biodiversity Conservation and
Sustainable Management of
Living Natural Resources was
updated in June 2019.
Source:JST based on the MDB’s SGPs below.
WB ESF: https://projects-beta.worldbank.org/en/projects-operations/environmental-and-social-framework
ADB SPS: https://www.adb.org/documents/safeguard-policy-statement
IFC SP: http://www.ifc.org/performancestandards

Details of the new WB ESF, which took effect in October 2018 are discussed in sections (2) and (3)
below.

Recent Revision / Update of MDBs’ SGPs

“JICA confirms that projects do not deviate significantly from the World Bank’s Safeguard Policies,
and refers as a benchmark to the standards of international financial organizations; to internationally

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recognized standards, or international standards, treaties, and declarations, etc.; and to the good
practices etc. of developed nations including Japan, when appropriate.” (JICA GL 2.6). In the
context of this policy, the current status about the revision and updates of SGPs of the WB, ADB
and IFC as well as their evaluations since the JICA GL took effect has been reviewed. The current
situation is summarized below. The WB approved the ESF in 2016, which took effect in October
2018. ADB announced that the evaluation of the application of the SPS would be conducted from
July 2018 to November 2019. Although IFC partially updated the GN corresponding to the PSs,
currently it is not revising the SGP.

Table 3-9 Status of MDBs’ SGPs and Their Revision


MDB Current SGPs Revision Status of SGPs
WB ESF approved in August 2016.  No
ESF took effect in October 2018.
ADB SPS approved in July 2009.  ADB’s Independent Evaluation Department is
SPS took effect six months after the approval. conducting “Corporate Evaluation of the Safeguard
Policy Statement”. The evaluation targets seven
countries (India, Papua New Guinea, China, Viet
Nam, Uzbekistan, Indonesia and Nepal) and is to
be carried out from July 2018 to November 2019.
The concept paper of the study was published in
September 2018. As of June 2019, the study results
have not been disclosed.
IFC Sustainability Framework took effect on January  No announcement on its website.
1st, 2012.
Source: JICA Study Team based on the website of MDBs.

The current JICA GL require that “the projects do not deviate significantly from the World Bank’s
Safeguard Policies.” The WB’s ESF and major changes from the previous OPs are summarized
below.

Three components of the ESF are as follows:

 A Vision for Sustainable Development: This sets out the Bank’s aspirations regarding
environmental and social sustainability.

 The WB Environmental and Social Policy for Investment Project Financing: This sets out the
mandatory requirements that apply to the WB.

 The ESSs: This, together with their Annexes, set out the mandatory requirements that apply to
the Borrower and projects. The requirements are grouped into 10 ESSs in a similar fashion to
IFC PSs.

Major changes from the previous SGPs can be summarized as follows:

1) Previously, safeguard requirements were articulated in independent OPs and Bank BPs. Now
they are integrated. The ESSs apply to all projects supported by the WB through Investment
Project Financing. Four new areas/topics that were not covered or articulated as a stand-alone
policy in the previous OPs/BPs are: Labor and Working Conditions (ESS2), Community Health

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and Safety (ESS4), Financial Intermediaries (ESS9) and Stakeholder Engagement and
Information Disclosure (ESS10).

2) Previously, the projects were screened and categorized as A, B, C or FI based on the type,
location, sensitivity and scale of the project. Under the Environmental and Social Policy, the
WB classifies all projects (including projects involving FIs) into one of four classifications:
high risk; substantial risk; moderate risk; and low risk. In determining the appropriate risk
classification, the Bank takes into account the relevant issues, such as type, location, sensitivity,
and scale of the project; the nature and magnitude of the potential environmental and social
risks and impacts; and the capacity and commitment of the Borrower. The WB reviews the risk
classification assigned to the project on a regular basis, including during implementation, and
may change the classification where necessary, to ensure that it continues to be appropriate.
(Environmental and Social Policy, para.20, 21)

3) The structure and contents of the SGP requirements are aligned with IFC and other MDBs’
SGPs and international good practices.

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3.3.2 Comparison of WB’s Previous SGPs with the New ESF


The table below shows the differences and major changes between the WB’s new ESF and the previous SGPs. Following table describes the WB ESF first and ESS. Direct quote from the texts of the SGPs are shown in Italic in the table.
Table 3-10 Major Differences between Previous SGPs and the ESF/ESS
Major Changes
(Unless otherwise specified, the
1) 2)
No Area New SGPs (ESF/ESS) Previous SGPs(OP) changes are new, additional
requirements under the new
ESF/ESS.)
1 Common <Environmental and Social Policy for Investment Project Financing> ・ No requirements regarding common approach are specified in the OPs. ・Introduction of common
Approach ・ Where the Bank is jointly financing a project with other multilateral or bilateral approach in co-financing projects
funding agencies, the Bank will cooperate with such agencies and the Borrower in
order to agree on a common approach for the assessment and management of
environmental and social risks and impacts of the project. A common approach
will be acceptable to the Bank, provided that such an approach will enable the
project to achieve objectives materially consistent with the ESSs. (para.9)
2 Categorization <Environmental and Social Policy for Investment Project Financing> <OP4.01: Environmental Assessment> ・New classification approach
of projects ・ The Bank will classify all projects (including projects involving Financial The Bank classifies the proposed project into one of four categories, depending on (High Risk, Substantial Risk,
Intermediaries (FIs)) into one of four classifications: High Risk, Substantial Risk, the type, location, sensitivity, and scale of the project and the nature and magnitude Moderate Risk, Low Risk)
Moderate Risk or Low Risk. In determining the appropriate risk classification, the of its potential environmental impacts.
Bank will take into account relevant issues, such as the type, location, sensitivity, (a.) Category A: A proposed project is classified as Category A if it is likely to have
and scale of the project; the nature and magnitude of the potential environmental significant adverse environmental impacts that are sensitive, diverse, or
and social risks and impacts; and the capacity and commitment of the Borrower unprecedented.
(including any other entity responsible for the implementation of the project) to (b.) Category B: A proposed project is classified as Category B if its potential adverse
manage the environmental and social risks and impacts in a manner consistent environmental impacts on human populations or environmentally important
with the ESSs. Other areas of risk may also be relevant to the delivery of areas--including wetlands, forests, grasslands, and other natural habitats--are
environmental and social mitigation measures and outcomes, depending on the less adverse than those of Category A projects.
specific project and the context in which it is being developed. […] The Bank will (c.) Category C: A proposed project is classified as Category C if it is likely to have
disclose the project’s classification and the basis for that classification on the minimal or no adverse environmental impacts.
Bank’s website and in project documents. (para.20) (d.) Category FI: A proposed project is classified as Category FI if it involves
・ The Bank will review the risk classification assigned to the project on a regular investment of Bank funds through a financial intermediary, in subprojects that
basis, including during implementation, and will change the classification where may result in adverse environmental impacts. (para 8)
necessary, to ensure that it continues to be appropriate. Any change to the
classification will be disclosed on the Bank’s website. (para.21)

3 Information <Environmental and Social Policy for Investment Project Financing> <OP4.01> ・ Disclosure of documentation
Disclosure ・ The Bank will disclose documentation relating to the environmental and social ・ Once the borrower officially transmits the Category A Environmental Assessment relating to the environmental
risks and impacts of High Risk and Substantial Risk projects prior to project (EA) report to the Bank, the Bank distributes the summary (in English) to the and social risks and impacts
appraisal. This documentation will […] be provided in draft or final form (if executive directors (EDs) and makes the report available through its InfoShop. prior to appraisal.
available). (para.51) Once the borrower officially transmits any separate Category B EA report to the

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Major Changes
(Unless otherwise specified, the
No Area New SGPs (ESF/ESS)1) Previous SGPs(OP)2) changes are new, additional
requirements under the new
ESF/ESS.)
・ There is no requirement in terms of the period of disclosure. Bank, the Bank makes it available through its InfoShop. (para.18)
4 Environmental <ESS1 Assessment and Management of Environmental and Social Risks and Impacts> <OP4.01> ・ Preparation of an
and Social ・ ESIA: The Borrower will carry out an environmental and social assessment of the ・ The Bank requires environmental assessment (EA of projects proposed for Bank environmental and social
Commitment project to assess the environmental and social risks and impacts of the project financing to help ensure that they are environmentally sound and sustainable, and impact assessment report,
Plan (ESCP) throughout the project life cycle. The assessment will be proportionate to the thus to improve decision making. (para.1) taking into account the
potential risks and impacts of the project, and will assess, in an integrated way, ・ EA takes into account the natural environment (air, water, and land); human requirements of ESS1-10
all relevant direct, indirect and cumulative environmental and social risks and health and safety; social aspects (involuntary resettlement, indigenous peoples, ・ Preparation of ESCP
impacts throughout the project life cycle, including those specifically identified in and physical cultural resources); and transboundary and global environmental
ESSs2–10. (para.23) aspects. (para.3)
・ ESCP: The Borrower will develop and implement an ESCP, which will set out ・ Depending on the project, a range of instruments can be used to satisfy the Bank's
measures and actions required for the project to achieve compliance with the ESSs EA requirement: environmental impact assessment, regional or sectoral EA,
over a specified timeframe. (para.36) strategic environmental and social assessment (SESA), environmental audit,
hazard or risk assessment, EMP and ESMF. (para.7)
5 ESIA Report <ESS1> <OP4.01> ・ Contents to be included in
・ The indicative outline of ESIA is provided in ESS1 Annex 1 D, which is: ・ Annex B of OP4.01 presents the contents to be included in the EA report. They ESIA reports (additional
(a) Executive Summary are: elements include: (e)
(b) Legal and Institutional Framework (a) Executive summary; environmental and Social
(c) Project Description (b) Policy, legal, and administrative framework; Risks; (h) design measures;
(d) Baseline Data (c) Project description; and (i) ESCP)
(e) Environmental and Social Risks and Impacts (d) Baseline data;
(f) Mitigation Measures (e) Environmental impacts;
(g) Analysis of Alternatives (f) Analysis of alternatives;
(h) Design Measures (g) EMP; and
(i) Key Measures and Actions for the ESCP (h) Appendixes.
(j) Appendices.

6 The use of <ESS1> <OP4.00 Piloting the Use of Borrower Systems to Address Environmental and Social ・ The use of the Borrower’s ES
Borrower’s ・ When a project is proposed for Bank support, the Borrower and the Bank will Safeguard Issues in Bank Supported Projects> Framework
ES consider whether to use all, or part, of the Borrower’s ES Framework in the ・ The Bank's environmental and social (“safeguard”) policies are designed to
Framework assessment, development and implementation of a project. Such use may be avoid, mitigate, or minimize adverse environmental and social impacts of projects
proposed provided this is likely to address the risks and impacts of the project, and supported by the Bank. The Bank encourages its borrowing member countries to
enable the project to achieve objectives materially consistent with the ESSs. adopt and implement systems that meet these objectives while ensuring that
(para.19) development resources are used transparently and efficiently to achieve desired
・ If the Borrower and the Bank propose to use all, or part, of the Borrower’s ES outcomes. To encourage the development and effective application of such
Framework, the Bank will review the Borrower’s ES Framework15 in accordance systems and thereby focus on building borrower capacity beyond individual

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Major Changes
(Unless otherwise specified, the
No Area New SGPs (ESF/ESS)1) Previous SGPs(OP)2) changes are new, additional
requirements under the new
ESF/ESS.)
with the requirement of paragraph 19. The Borrower will provide information to project settings, the Bank is piloting the use of borrower systems in Bank-
the Bank in connection with the assessment. (para.20) supported projects. The key objective of the pilot program is to improve overall
understanding of implementation issues related to greater use of country systems.
(para.1)
・ The Bank considers a borrower's environmental and social safeguard system to
be equivalent to the Bank's if the borrower's system is designed to achieve the
objectives and adhere to the applicable operational principles set out in Table
A1 1. (para.2)
7 Analysis of <ESS1> <OP4.01> ・No differences
Alternatives ・ The methodology and requirements in relation to the analysis of alternatives are ・ The methodology and requirements in relation to the analysis of alternatives are
articulated in Annex 1 D (g) of ESS1. They are: articulated in Annex B, f), which is:
- Systematically compares feasible alternatives to the proposed project site, - Analysis of alternatives. Systematically compares feasible alternatives to the
technology, design, and operation—including the “without project” situation—in proposed project site, technology, design, and operation--including the "without
terms of their potential environmental and social impacts. project" situation--in terms of their potential environmental impacts; the
- Assesses the alternatives’ feasibility of mitigating the environmental and social feasibility of mitigating these impacts; their capital and recurrent costs; their
impacts; the capital and recurrent costs of alternative mitigation measures, and suitability under local conditions; and their institutional, training, and
their suitability under local conditions; and the institutional, training, and monitoring requirements. For each of the alternatives, quantifies the
monitoring requirements for the alternative mitigation measures. environmental impacts to the extent possible, and attaches economic values
- For each of the alternatives, quantifies the environmental and social impacts to where feasible. States the basis for selecting the particular project design
the extent possible, and attaches economic values where feasible. proposed and justifies recommended emission levels and approaches to pollution
prevention and abatement.
8 Quantification <ESS1> <OP4.01> ・No differences
of costs and ・ For each of the alternatives, quantifies the environmental and social impacts to ・ For each of the alternatives, quantifies the environmental impacts to the extent
benefits the extent possible, and attaches economic values where feasible. (ESS 1 possible, and attaches economic values where feasible. (Annex B)
Annex1D (g))
9 Associated <ESS1> ・ The definition of associated facilities, indirect and secondary impacts, and ・ The definition of associated
Facilities, ・ For the purpose of this ESS, the term “Associated Facilities” means facilities or cumulative impacts are not specified in OP. facilities, indirect and
Indirect activities that are not funded as part of the project and are: (a) directly and secondary impacts, and
Impacts, and significantly related to the project; (b) carried out, or planned to be carried out, cumulative impacts
Cumulative contemporaneously with the project; and (c) necessary for the project to be
Impacts viable and would not have been constructed, expanded or conducted if the project
did not exist. (para.11)
・ Associated Facilities will meet the requirements of the ESSs, to the extent that the

1
Environmental and Social Safeguard Policies—Policy Objectives and Operational Principles (https://policies.worldbank.org/sites/ppf3/PPFDocuments/Environmental%20and%20social%20safeguard%20policie.pdf)

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Major Changes
(Unless otherwise specified, the
No Area New SGPs (ESF/ESS)1) Previous SGPs(OP)2) changes are new, additional
requirements under the new
ESF/ESS.)
Borrower has control or influence over such Associated Facilities (para.10)
・ An indirect impact is an impact which is caused by the project and is later in time
or farther removed in distance than a direct impact, but is still reasonably
foreseeable, and will not include induced impacts. (footnote 21)
・ The cumulative impact of the project is the incremental impact of the project when
added to impacts from other relevant past, present and reasonably foreseeable
developments as well as unplanned but predictable activities enabled by the
project that may occur later or at a different location. Cumulative impacts can
result from individually minor but collectively significant activities taking place
over a period of time. The environmental and social assessment will consider
cumulative impacts that are recognized as important on the basis of scientific
concerns and/ or reflect the concerns of project-affected parties. The potential
cumulative impacts will be determined as early as possible, ideally as part of
project scoping. (footnote 22)
10 Labor <ESS2 Labor and Working Conditions> ・ No OPs specify requirements regarding types of project worker, LMP, OHSM, ・ Types of project worker, LMP,
・ The requirements of the borrower in relation to labor and working conditions are and Grievance Mechanism for Workers. OHSM, and Grievance
newly added to the WB’s SGP. Mechanism for Workers
・ The scope of application of ESS2 depends on the type of employment relationship
between the Borrower and the project workers. The term “project worker” refers
to:
(a) people employed or engaged directly by the Borrower (including the project
proponent and the project implementing agencies) to work specifically in
relation to the project (direct workers);
(b) people employed or engaged through third parties to perform work related to
core functions of the project, regardless of location (contracted workers);
(c) people employed or engaged by the Borrower’s primary suppliers (primary
supply workers); and
(d) people employed or engaged in providing community labor (community
workers). (para.3)
・ The specific requirements depend on the type of project worker. For example,
Labour Management Procedure (LMP), Occupational Health and Safety Measure
(OHSM) and Grievance Mechanism, described below, are applies to (a) direct
workers and (b) contracted workers. LMP and OHSM are partially applied to (c)
primary supply workers, depending on scale and nature of the project, and for (d)
community workers, the below are not required but corrective actions may be

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Major Changes
(Unless otherwise specified, the
No Area New SGPs (ESF/ESS)1) Previous SGPs(OP)2) changes are new, additional
requirements under the new
ESF/ESS.)
required when obvious and significant issues such as child labour and/or forced
labour are found. (para. 4-8)
・ LMP: Set out such as working hours, wages, overtime, compensation and benefits,
nondiscrimination and equal opportunity, protection of vulnerable workers,
protection of rights to form/join workers’ organizations, no child labour/forced
labour. (para. 9-20)
・ OHSM: The OHS measures will be prepared, taking into account General EHSG
and, as appropriate, the industry-specific EHSGs and other GIIP. (para.24) These
measures are to be prepared by the borrower and implemented/supervised by the
contractor.
・ Grievance Mechanism: It is required that a grievance mechanism be provided for
all direct and contracted workers, and where relevant, for their organizations.
(para.21)
11 Estimation of <ESS3 Resource Efficiency and Pollution Prevention and Management> <OP4.01> ・ Estimation of GHG emissions
GHG ・ The borrower will estimate gross GHG emissions resulting from the project, ・ EA takes into account the natural environment (air, water, and land); human resulting from the project
emissions providing that such estimation is technically and financially feasible. (para.16) health and safety; social aspects (involuntary resettlement, indigenous peoples,
Estimation scope is only Scope 1 in order to avoid double counting. (GN16.1) and physical cultural resources); transboundary and global environmental
・ For projects that have diverse and small sources of emissions (for example, aspects. (para.3)
community-driven development projects) or where emissions are not likely to be ・ Global environmental issues include climate change, ozone-depleting substances,
significant (for example, projects in education and social protection), GHG pollution of international waters, and adverse impacts on biodiversity. (footnote
estimations will not be required. (para.16) 5)
・ The threshold of significance (the amount above which requires GHG estimation) ・ Procedures and requirements regarding estimation of GHG emission are not
is not specified in ESS. specified in OP.
・ GHG estimation will be done only once before project commencement as a part of
ESIA of the project. (para 16)
・ The ESIA including the GHG estimation is disclosed, based on the risk
classification of the project.
12 GHG <ESS3> ・ No OPs specify requirements of conducting alternative analysis to avoid or ・ Alternative analysis of
emission for ・ Analysis of alternatives to avoid or minimize GHG emissions: The Borrower will minimize project-related GHG emissions. technically and financially
alternative consider alternatives and implement technically and financially feasible and cost- feasible and cost-effective
analysis effective options to avoid or minimize project-related air emissions during the options to avoid or minimize
design, construction and operation of the project. (para.15) project-related GHG
emissions
13 Management <ESS3> ・ No OPs specify requirements concerning hazardous wastes, chemicals and ・ Requirements concerning
of hazardous ・ The Borrower will avoid the generation of hazardous and nonhazardous waste. hazardous materials. hazardous wastes, chemicals

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Major Changes
(Unless otherwise specified, the
No Area New SGPs (ESF/ESS)1) Previous SGPs(OP)2) changes are new, additional
requirements under the new
ESF/ESS.)
wastes, Where waste generation cannot be avoided, the Borrower will minimize the ・ In assisting borrowers to manage pests that affect either agriculture or public and hazardous materials
chemicals, generation of waste, and reuse, recycle and recover waste in a manner that is safe health, the Bank supports a strategy that promotes the use of biological or
hazardous for human health and the environment. Where waste cannot be reused, recycled or environmental control methods and reduces reliance on synthetic chemical
materials and recovered, the Borrower will treat, destroy, or dispose of it in an environmentally pesticides. In Bank-financed projects, the borrower addresses pest management
pesticides sound and safe manner that includes the appropriate control of emissions and issues in the context of the project's environmental assessment. (OP4.09 Pest
residues resulting from the handling and processing of the waste material. Management, para.1)
(para.17) ・ The Bank uses various means to assess pest management in the country and
・ The Borrower will avoid the manufacture, trade and use of chemicals and support IPM and the safe use of agricultural pesticides. (OP4.09, para.3)
hazardous materials subject to international bans, restrictions or phaseouts unless ・ The following criteria apply to the selection and use of pesticides in Bank-
for an acceptable purpose as defined by the conventions or protocols or if an financed projects:
exemption has been obtained by the Borrower, consistent with Borrower (a) They must have negligible adverse human health effects.
government commitments under the applicable international agreements. (b) They must be shown to be effective against the target species.
(para.19) (c) They must have minimal effect on nontarget species and the natural
・ Where projects involve recourse to pest management measures, the Borrower will environment.
give preference to integrated pest management (IPM) or integrated vector (d) Their use must take into account the need to prevent the development of
management (IVM) approaches using combined or multiple tactics. (para.21) resistance in pests. (OP4.09, para.6)
・ The Borrower will not use any pesticides or pesticide products or formulations
unless such use is in compliance with the EHSGs. (para.22)
・ For any project involving significant pest management issues or any project
contemplating activities that may lead to significant pest and pesticide
management issues, the Borrower will prepare a Pest Management Plan (PMP).
(para.25)
14 Community <ESS4 Community Health and Safety> ・ The OPs do not address specifically the risk associated with influx of labor, ・ Adding new considerations on
Health and ・ The Borrower will identify and implement measures to address emergency events. security personnel and community safety. The requirement and contents of ERP emergency responses,
Safety (para.19) are not covered either. hazardous waste, influx of
・ Borrowers engaged in projects having the potential to generate emergency events ・ The impact and risks of climate change are not taken into account in design of workers, risks of security
will conduct a risk hazard assessment […] the Borrower will prepare an structural elements or components of a project. personnel, safety of the
Emergency Response Plan (ERP) in coordination with the relevant local affected communities
authorities and the affected community. (para.20) ・ When the Bank finances a project that includes the construction of a new dam, it ・ Consideration of climate
・ Regarding the safety of dams, the Borrower will engage experienced and requires that the dam be designed and its construction supervised by experienced change impacts and risks in
competent professionals for the supervision of the design and construction of new and competent professionals. It also requires that the borrower adopt and design of structural elements
dams, and require the owner of the dam to adopt and implement dam safety implement certain dam safety measures for the design, bid tendering, or components of a project
measures during the design, bid tendering, construction, operation, and construction, operation, and maintenance of the dam and associated works.
maintenance of the dam and associated works. (Annex 1A, para.1) (OP4.37 Safety of Dams, para.2)
・ Where the risks and impacts of community exposure to hazardous materials and

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Major Changes
(Unless otherwise specified, the
No Area New SGPs (ESF/ESS)1) Previous SGPs(OP)2) changes are new, additional
requirements under the new
ESF/ESS.)
wastes are potentially significant, it may be appropriate to develop a Hazardous
Waste Management Plan or a Hazardous Materials Management Plan. The
Hazardous Materials Management Plans should set out, at a minimum, the
organizational arrangements and responsibilities for hazardous material
identification, storage, handling, use, and disposal, including the processes for
monitoring and managing the risks and for implementing the necessary mitigation
measures throughout the project life cycle. (GN 18.4)
・ The Borrower will take measures to avoid or minimize transmission of
communicable diseases that may be associated with the influx of temporary or
permanent project labor. (para.16)
・ The WB’s GN on Managing Risks Related to Labor Influx (2016) articulates three
principles to manage the risks of adverse impacts on communities that may result
from temporary project induced labor influx. They are:
- Reduce labor influx by tapping into the local workforce;
- Assess and manage labor influx risk based on appropriate instruments; and
- Incorporate social and environmental mitigation measures into the civil works
contract.
・ When the Borrower retains direct or contracted workers to provide security to
safeguard its personnel and property, it will assess risks posed by these security
arrangements to those within and outside the project site. (para.24) The Borrower
will review all allegations of unlawful or abusive acts of security personnel, take
action (or urge appropriate parties to take action) to prevent recurrence and,
where necessary, report unlawful and abusive acts to the relevant authorities.
(para. 27)
・ The Borrower will design, construct, operate, and decommission the structural
elements of the project in accordance with national legal requirements, the
EHSGs and other GIIP, taking into consideration safety risks to third parties and
affected communities. (para.6)
・ When structural elements or components of a project are situated in high-risk
locations, including those with risk of extreme weather or slow onset events, and
their failure or malfunction may threaten the safety of communities, the Borrower
will engage one or more independent experts with relevant and recognized
experience in similar projects, separate from those responsible for the design and
construction, to conduct a review as early as possible in project development and
throughout the stages of project design, construction, operation, and

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ESF/ESS.)
decommissioning. (para.8)
15 Land <ESS5 Land Acquisition, Restrictions on Land Use and Involuntary Resettlement> <OP4.12 Involuntary Resettlement> ・Elements to be included in a
Acquisition, ・ This ESS applies to permanent or temporary physical and economic displacement ・ This policy covers direct economic and social impacts that both result from Bank- resettlement plan (the
Resettlement resulting from the following types of land acquisition or restrictions on land use assisted investment projects, and are caused by requirements in the case of
undertaken or imposed in connection with project implementation. (para.4 ) (a) the involuntary taking of land resulting in physical relocation and
・ Compensation will be made at replacement cost. There is no major change in the (i) relocation or loss of shelter; economic relocation are
definition of replacement compared with OP4.12. In this ESS, replacement cost is (ii) loss of assets or access to assets; or distinguished in ESS5).
defined as the market value as established through independent and competent real (iii) loss of income sources or means of livelihood, whether or not the affected
estate valuation, plus transaction costs when there is functional market, and where persons must move to another location; or
functioning markets do not exist, replacement cost may be determined through (b) the involuntary restriction of access to legally designated parks and protected
alternative means, such as calculation of output value for land or productive areas resulting in adverse impacts on the livelihoods of the displaced persons.
assets, or the undepreciated value of replacement material and labor for (para.3)
construction of structures or other fixed assets, plus transaction costs. (footnote 6) ・ “Replacement cost” is the method of valuation of assets that helps determine the
・ Compensation standards for categories of land and fixed assets will be disclosed amount sufficient to replace lost assets and cover transaction costs. In applying
and applied consistently. […] a clear basis for calculation of compensation will be this method of valuation, depreciation of structures and assets should not be taken
documented, and compensation distributed in accordance with transparent into account. (footnote.11)
procedures. (para.13) ・ As a condition of appraisal of projects involving resettlement, the borrower
・ For relocation of persons who have no recognizable legal right or claim to the land provides the Bank with the relevant draft resettlement instrument which conforms
or assets they occupy or use, the Borrower will provide arrangements to allow to this policy, and makes it available at a place accessible to displaced persons
them to obtain adequate housing with security of tenure. Where these displaced and local NGOs, in a form, manner, and language that are understandable to them.
persons own structures, the Borrower will compensate them for the loss of assets (para.22)
other than land, such as dwellings and other improvements to the land, at ・ Those who have no recognizable legal right or claim to the land they are occupying
replacement cost. (para.29) are provided resettlement assistance in lieu of compensation for the land they
・ The 200 people threshold for preparing the resettlement plan and abbreviated occupy, and other assistance, as necessary, to achieve the objectives set out in this
resettlement plan in OP4.12 is deleted and the Borrower will prepare a plan policy, if they occupy the project area prior to a cut-off date established by the
proportionate to the risks and impacts associated with the project (para.21). ESS5 borrower and acceptable to the Bank. (para.16)
does not specify the quantitative threshold of involuntary resettlement to prepare ・ A resettlement plan or abbreviated resettlement plan is required for all operations
the resettlement plan. that entail involuntary resettlement unless otherwise specified. (para.17 (a))
・ Valuation of and compensation for losses and transitional support, which are ・ A draft resettlement plan that conforms to this policy is a condition of appraisal
components of RAP, are described as follows: […] for projects referred to in para. 17(a) above. However, where impacts on the
(a) Valuation of and compensation for losses: [t]he methodology to be used in entire displaced population are minor, or fewer than 200 people are displaced, an
valuing losses to determine their replacement cost; and a description of the abbreviated resettlement plan may be agreed with the borrower. (para.25)
proposed types and levels of compensation for land, natural resources and ・ Where domestic law does not meet the standard of compensation at full
other assets under local law and such supplementary measures as are necessary replacement cost, compensation under domestic law is supplemented by additional
to achieve replacement cost for them. (para 10, ESS 5 Annex 1) measures necessary to meet the replacement cost standard. (footnote.11)

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(b) Transitional support: [t]he resettlement plan provides transitional support to ・ Displaced persons are (i) offered support after displacement, for a transition
those whose livelihood will be disrupted. This may include payment for lost period, based on a reasonable estimate of the time likely to be needed to restore
crops and lost natural resources, payment of lost profits for businesses, or their livelihood and standards of living (para.6 (c))
payment of lost wages for employees affected by business relocation. The plan ・ Elements to be included in a resettlement plan is described in Annex A of OP4.12.
provides that the transitional support continues for the duration of the They are:
transition period. (para 29, ESS5 Annex 1) - Description of the project;
・ Minimum elements of a resettlement plan are provided in Annex 1 A, which are: - Potential impacts;
- Description of the project - Objectives;
- Potential impacts - Socioeconomic studies;
- Objectives - Legal framework;
- Census survey and baseline socioeconomic studies - Institutional Framework;
- Legal framework - Eligibility;
- Institutional framework - Valuation of and compensation for losses;
- Eligibility - Resettlement measures;
- Valuation of and compensation for losses - Site selection, site preparation, and relocation;
- Community participation - Housing, infrastructure, and social services;
- Implementation schedule - Environmental protection and management;
- Costs and budget - Community participation;
- Grievance redress mechanism - Integration with host populations;
- Monitoring and evaluation - Grievance procedures;
- Arrangements for adaptive management. - Organizational responsibilities;
・ In addition to the above, resettlement plans require additional information and - Implementation schedule;
planning Elements when project circumstances require the physical relocation of - Costs and budget; and
residents (or businesses). They are: - Monitoring and evaluation.
- Transitional assistance
- Site selection, site preparation, and relocation
- Housing, infrastructure, and social services
- Environmental protection and management
- Consultation on relocation arrangements
- Integration with host populations.
・ In addition to above-mentioned elements, in case of physical displacement,
transitional assistance for relocation of household members and their possessions;
site selection, site preparation, and relocation, housing, infrastructure, and social
services; environmental protection and management; consultation on relocation
arrangements; and integration with host populations are included in the

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ESF/ESS.)
resettlement plan (para 17-23, ESS 5, Annex 1). Moreover, if any economic
displacement, replacement of farmland, loss of access to land or resources, support
for alternative livelihoods, consideration of economic development opportunities,
and transitional support for livelihoods are included in the resettlement plan (para
24-29, ESS 5 Annex 1).
16 Classification <ESS6 Biodiversity Conservation and Sustainable Management of Living Natural <OP4.04 Natural Habitats> ・ Classification of habitats and
of Habitat Resources> ・ Natural habitats are land and water areas where (i) the ecosystems' bio-logical approach for risk management
・ “Habitat” is defined as a terrestrial, freshwater, or marine geographical unit or communities are formed largely by native plant and animal species, and (ii) human
airway that supports assemblages of living organisms and their interactions with activity has not essentially modified the area's primary ecological functions. All
the nonliving environment. (para.13) The definition of three different types of natural habitats have important biological, social, economic, and existence value.
habitats and the requirements of implementing a project in these habitats are Important natural habitats may occur in tropical humid, dry, and cloud forests;
articulated in this ESS as follows: temperate and boreal forests; mediterranean-type shrub lands; natural arid and
- Modified habitats are areas that may contain a large proportion of plant and/or semi-arid lands; mangrove swamps, coastal marshes, and other wetlands;
animal species of nonnative origin, and/or where human activity has substantially estuaries; sea grass beds; coral reefs; freshwater lakes and rivers; alpine and sub
modified an area’s primary ecological functions and species composition. alpine environments, including herb fields, grasslands, and paramos; and tropical
(para.19) and temperate grasslands. (Annex A para 1. a)
- Natural habitats are areas composed of viable assemblages of plant and/or ・ Critical natural habitats are:
animal species of largely native origin, and/or where human activity has not (i) existing protected areas and areas officially proposed by governments as
essentially modified an area’s primary ecological functions and species protected areas (e.g., reserves that meet the criteria of the World Conservation
composition. (para.21) Union [IUCN] classifications), areas initially recognized as protected by
- Critical habitat is defined as areas with high biodiversity importance or value, traditional local communities (e.g., sacred groves), and sites that maintain
including: conditions vital for the viability of these protected areas (as determined by the
(a) habitat of significant importance to Critically Endangered or Endangered environ-mental assessment process); or
species, as listed in the IUCN Red List of threatened species or equivalent national (ii) sites identified on supplementary lists prepared by the Bank or an authoritative
approaches; source determined by the Regional environment sector unit (RESU). Such sites
(b) habitat of significant importance to endemic or restricted-range species; may include areas recognized by traditional local communities (e.g., sacred
(c) habitat supporting globally or nationally significant concentrations of groves); areas with known high suitability for bio-diversity conservation; and sites
migratory or congregatory species; that are critical for rare, vulnerable, migratory, or endangered species.4 Listings
(d) highly threatened or unique ecosystems; are based on systematic evaluations of such factors as species richness; the degree
(e) ecological functions or characteristics that are needed to maintain the viability of endemism, rarity, and vulnerability of component species; representativeness;
of the biodiversity values described above in (a) to (d). (para.23) and integrity of ecosystem processes. (Annex A para 1. b)
・ For modified habitat, the Borrower will avoid or minimize impacts on such ・ The Bank does not support projects that, in the Bank's opinion, involve the
biodiversity and implement mitigation measures as appropriate. (para.20) significant conversion or degradation of critical natural habitats. (para.4)
・ For natural habitat the Borrower will seek to avoid adverse impacts on them in ・ The Bank does not support projects involving the significant conversion of natural
accordance with the mitigation hierarchy. Where natural habitats have the habitats unless there are no feasible alternatives for the project and its siting, and

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requirements under the new
ESF/ESS.)
potential to be adversely affected by the project, the Borrower will not implement comprehensive analysis demonstrates that overall benefits from the project
any project-related activities unless: substantially outweigh the environmental costs. If the environmental assessment4
(a) There are no technically and financially feasible alternatives; and indicates that a project would significantly convert or degrade natural habitats,
(b) Appropriate mitigation measures are put in place, in accordance with the the project includes mitigation measures acceptable to the Bank. (para.5)
mitigation hierarchy, to achieve no net loss and, where feasible, preferably a net ・ No OPs specify the requirement of BMP or include reference related to the
gain of biodiversity over the long term. When residual impacts remain despite best applicability of offset.
efforts to avoid, minimize and mitigate impacts, and where appropriate and
supported by relevant stakeholders, mitigation measures may include biodiversity
offsets adhering to the principle of “like-for-like or better.” (para.22)
・ For critical habitat, the Borrower will not implement any project activities that
have potential adverse impacts unless all of the following conditions are met:
(a) No other viable alternatives within the region exist for development of the
project in habitats of lesser biodiversity value;
(b) All due process required under international obligations or national law that is
a prerequisite to a country granting approval for project activities in or adjacent to
a critical habitat has been complied with;
(c) The potential adverse impacts, or likelihood of such, on the habitat will not
lead to measurable net reduction or negative change in those biodiversity values
for which the critical habitat was designated;
(d) The project is not anticipated to lead to a net reduction in the population13 of
any Critically Endangered, Endangered, or restricted-range species, over a
reasonable time period;
(e) The project will not involve significant conversion or significant degradation of
critical habitats. In circumstances where the project involves new or renewed
forestry or agricultural plantations, it will not convert or degrade any critical
habitat;
(f) The project’s mitigation strategy will be designed to achieve net gains of those
biodiversity values for which the critical habitat was designated; and
(g) A robust and appropriately designed, long term biodiversity monitoring and
evaluation program aimed at assessing the status of the critical habitat is
integrated into the Borrower’s management program. (para.24)

・ Biodiversity Management Plan (BMP): Where significant risks and adverse


impacts on biodiversity have been identified, the Borrower will develop and
implement a BMP. BMP consists of objectives, activities, mitigation measures,

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ESF/ESS.)
implementation schedule, institutional responsibilities and cost estimates (para 9,
ESS 6 & GN Appendix 1).
・ Offsets will be considered as a last resort, only if significant residual adverse
impacts remain after all technically and financially feasible avoidance,
minimization, and restoration measures have been considered. (para.15)
・ A biodiversity offset will be designed and implemented to achieve measurable,
additional, and long term conservation outcomes that can reasonably be expected
to result in no net loss and preferably a net gain of biodiversity. In the case of an
offset used as mitigation for residual adverse impacts on any area of critical
habitat, a net gain is required. (para.16)
17 Protected <ESS6> <OP4.04> ・ Definition of protected area,
Area ・ Where the project occurs within or has the potential to adversely affect an area ・ Existing protected areas and areas officially proposed by governments as and conditions of
that is legally protected, designated for protection, or regionally or internationally protected areas (e.g., reserves that meet the criteria of the World Conservation implementing a project within
recognized, the Borrower will ensure that any activities undertaken are consistent Union [IUCN] classifications) is considered as critical habitat in OP4.04. (Annex protected area
with the area’s legal protection status and management objectives. (para.26) A para 1. b)
・ Internationally recognized areas of high biodiversity value include World Heritage ・ The Bank does not support projects that, in the Bank's opinion, involve the
Natural Sites, Biosphere Reserves, Ramsar Wetlands of International Importance, significant conversion or degradation of critical natural habitats. (para.4)
Key Biodiversity Areas, Important Bird Areas, and Alliance for Zero Extinction
Sites, among others. (footnote 16)
It does not mean that implementation of the project is prohibited in these protected
area; however, to implement the project, certain conditions need to be met.
・ In addition to meeting applicable requirements in this ESS, the Borrower will do
the following to implement a project in protected area:
(a) Demonstrate that the proposed development in such areas is legally permitted;
(b) Act in a manner consistent with any government recognized management plans
for such areas;
(c) Consult and involve protected area sponsors and managers, project-affected
parties including Indigenous Peoples, and other interested parties on planning,
designing, implementing, monitoring, and evaluating the proposed project, as
appropriate; and
(d) Implement additional programs, as appropriate, to promote and enhance the
conservation aims and effective management of the area. (para.27)
・ If the project area falls one of the habitats, the borrower needs to meet the
requirements in the protected area to implement the project in addition to
requirements in the habitats.

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ESF/ESS.)
18 Indigenous <ESS7 Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional <OP4.10 Indigenous Peoples> ・ Definition of FPIC
Peoples Local Communities (IP/SSAHUTLC)> ・ For purposes of this policy, the term “Indigenous Peoples” is used in a generic ・ In ESS7, the term of
・ In this ESS, the term “Indigenous Peoples/Sub-Saharan African Historically sense to refer to a distinct, vulnerable, social and cultural group6 possessing the “IP/SSAHUTLC” is used
Underserved Traditional Local Communities” […] is used in a generic sense to following characteristics in varying degrees: instead of “Indigenous
refer exclusively to a distinct social and cultural group possessing the following (a) self-identification as members of a distinct indigenous cultural group and Peoples”
characteristics in varying degrees: recognition of this identity by others;
(a) Self-identification as members of a distinct indigenous social and cultural (b) collective attachment to geographically distinct habitats or ancestral
group and recognition of this identity by others; and territories in the project area and to the natural resources in these habitats and
(b) Collective attachment6 to geographically distinct habitats, ancestral territories
territories, or areas of seasonal use or occupation, as well as to the natural (c) customary cultural, economic, social, or political institutions that are separate
resources in these areas; and from those of the dominant society and culture; and
(c) Customary cultural, economic, social, or political institutions that are distinct (d) an indigenous language, often different from the official language of the
or separate from those of the mainstream society or culture; and country or region. (para.4)
(d) A distinct language or dialect, often different from the official language or ・ Where the project affects Indigenous Peoples, the borrower engages in free, prior,
languages of the country or region in which they reside. (para.8) and informed consultation with them. (para.10)
・ The borrower will propose measures and actions in consultation with the affected ・ In deciding whether to proceed with the project, the borrower ascertains, on the
Indigenous Peoples/ Sub-Saharan African Historically Underserved Traditional basis of the social assessment […] and the free, prior, and informed consultation
Local Communities and contained in a time-bound plan, such as an Indigenous […], whether the affected Indigenous Peoples’ communities provide their broad
Peoples/Sub-Saharan African Historically Underserved Traditional Local support to the project. (para.11)
Communities plan. (para.13) ・ Annex B of OP4.10 presents elements to be included in the Indigenous Peoples
・ When Indigenous Peoples/Sub-Saharan African Historically Underserved Plan (IPP). They are:
Traditional Local Communities are the sole, or the overwhelming majority of, - A summary of the social assessment;
project beneficiaries, the elements of the plan may be included in the overall - A summary of results of the free, prior, and informed consultation with the
project design, and preparation of a stand-alone Indigenous Peoples/Sub-Saharan affected Indigenous Peoples’ communities that was carried out during project
African Historically Underserved Traditional Local Communities plan is not preparation;
necessary. (para.15) - A framework for ensuring free, prior, and informed consultation with the affected
・ In some circumstances, a broader integrated community development plan10 will Indigenous Peoples’ communities during project implementation;
be prepared, addressing all beneficiaries of the project and incorporating - An action plan of measures to ensure that the Indigenous Peoples receive social
necessary information relating to the affected Indigenous Peoples/Sub-Saharan and economic benefits;
African Historically Underserved Traditional Local Communities. (para.17) - An appropriate action plan of measures to avoid, minimize, mitigate, or
・ When IP/SSAHUTLC are the target of resettlement, a resettlement plan can be compensate for these adverse effects;
prepared separately or combined, as appropriate, as long as the process is in line - The cost estimates and financing plan;
with the conclusion of the FPIC process and in accordance with ESS5. (GN 31.2) - Accessible procedures appropriate to the project to address grievances by the
・ This ESS defines the scope and application of FPIC as follows: affected Indigenous Peoples' communities arising from project implementation;
(a) The scope of FPIC applies to project design, implementation arrangements and and.

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No Area New SGPs (ESF/ESS)1) Previous SGPs(OP)2) changes are new, additional
requirements under the new
ESF/ESS.)
expected outcomes related to risks and impacts on the affected Indigenous - Mechanisms and benchmarks appropriate to the project for monitoring,
Peoples/Sub-Saharan African Historically Underserved Traditional Local evaluating, and reporting on the implementation of the IPP.
Communities;
(b) FPIC builds on and expands the process of meaningful consultation […], and
will be established through good faith negotiation between the Borrower and
affected Indigenous Peoples/ Sub-Saharan African Historically Underserved
Traditional Local Communities;
(c) The Borrower will document: (i) the mutually accepted process to carry out
good faith negotiations that has been agreed by the Borrower and Indigenous
Peoples/Sub-Saharan African Historically Underserved Traditional Local
Communities; and (ii) the outcome of the good faith negotiations between the
Borrower and Indigenous Peoples/Sub-Saharan African Historically Underserved
Traditional Local Communities, including all agreements reached as well as
dissenting views; and
(d) FPIC does not require unanimity and may be achieved even when individuals
or groups within or among affected Indigenous Peoples/ Sub-Saharan African
Historically Underserved Traditional Local Communities explicitly disagree. (para.
25)
・ Indicative outline of IP/SSAHUTLC plan is provided in Appendix A of the
Guidance Note for ESS7, which is:
1. A summary of the Targeted Social Assessment
2. A summary of the results of the meaningful consultation tailored to
IP/SSAHUTLC
3. A framework for meaningful consultation tailored to IP/SSAHUTLC during
project implementation
4. Measures for ensuring IP/SSAHUTLC receive social and economic benefits that
are culturally appropriate and gender sensitive and steps for implementing them.
5. Measures to avoid, minimize, mitigate, or compensate IP/SSAHUTLC for any
potential adverse impacts that were identified in the social assessment, and steps
for implementing them
6. The cost estimates, financing plan, schedule, and roles and responsibilities for
implementing the IP/SSAHUTLC Plan
7. Accessible procedures appropriate to the project to address grievances by the
affected IP/SSAHUTLC arising from project implementation; and
8. Mechanisms and benchmarks appropriate to the project for monitoring,

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ESF/ESS.)
evaluating, and reporting on the implementation of the IP/SSAHUTLC Plan.
19 Cultural <ESS8 Cultural Heritage> <OP4.11 Physical Cultural Resources> ・ Intangible cultural heritage is
Heritage ・ This ESS applies to both tangible and intangible cultural heritage. The definition of ・ This policy addresses physical cultural resources,1 which are defined as movable added in ESS8
tangible and intangible cultural heritage provided in ESS8 are as follows: or immovable objects, sites, structures, groups of structures, and natural features
- Tangible cultural heritage includes movable or immovable objects, sites, and landscapes that have archaeological, paleontological, historical,
structures, groups of structures, and natural features and landscapes that have architectural, religious, aesthetic, or other cultural significance. Physical cultural
archaeological, paleontological, historical, architectural, religious, aesthetic, or resources may be located in urban or rural settings, and may be above or below
other cultural significance. Tangible cultural heritage may be located in urban or ground, or under water. Their cultural interest may be at the local, provincial or
rural settings, and may be above or below land or under the water; and national level, or within the international community. (para.1)
- Intangible cultural heritage includes practices, representations, expressions, ・ As an integral part of the EA process, the borrower develops a physical cultural
knowledge, skills—as well as the instruments, objects, artifacts and cultural spaces resources management plan that includes measures for avoiding or mitigating any
associated therewith— that communities and groups recognize as part of their adverse impacts on physical cultural resources, provisions for managing chance
cultural heritage, as transmitted from generation to generation and constantly finds, any necessary measures for strengthening institutional capacity, and a
recreated by them in response to their environment, their interaction with nature monitoring system to track the progress of these activities. The physical cultural
and their history. (para. 4) resources management plan is consistent with the country’s overall policy
・ The requirements of this ESS8 will apply to all projects that are likely to have risks framework and national legislation and takes into account institutional
or impacts on cultural heritage. This will include a project which: capabilities with regard to physical cultural resources. (para.9)
(a) Involves excavations, demolition, movement of earth, flooding or other changes ・ No OPs specify requirements regarding intangible cultural heritage.
in the physical environment
(b) Is located within a legally protected area or a legally defined buffer zone
(c) Is located in, or in the vicinity of, a recognized cultural heritage site or
(d) Is specifically designed to support the conservation, management and use of
cultural heritage. (para.5)
・ The requirements of ESS8 apply to cultural heritage regardless of whether or not it
has been legally protected or previously identified or disturbed. (para.6)
・ The Borrower will avoid impacts on cultural heritage. When avoidance of impacts
is not possible, the Borrower will identify and implement measures to address
impacts on cultural heritage in accordance with the mitigation hierarchy.1 Where
appropriate, the Borrower will develop a Cultural Heritage Management Plan.
(para.9)
・ A project-specific chance finds procedure will be followed if previously unknown
cultural heritage is encountered during project activities. (para.11)
20 FI <ESS9 Financial Intermediaries> <OP4.01> ・ Application of requirements
・ This ESS applies to Financial Intermediaries (FIs) that receive financial support ・ For a project involving a FI, the Bank requires that each FI screen proposed depending on the risks and
from the Bank. (para.4) subprojects and ensure that subborrowers carry out appropriate EA for each impacts and development of

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(Unless otherwise specified, the
No Area New SGPs (ESF/ESS)1) Previous SGPs(OP)2) changes are new, additional
requirements under the new
ESF/ESS.)
・ The requirements of this ESS apply to all FIs that receive support from the Bank, subproject. Before approving a subproject, the FI verifies […] that the subproject ESMS for FI projects
either directly from the Bank or the Borrower, or through the Borrower or other meets the environmental requirements of appropriate national and local
FIs, as follows: authorities and is consistent with this OP and other applicable environmental
(a) Where Bank support is provided to the FI to fund clearly defined FI policies of the Bank. (para.10)
subprojects, the requirements of this ESS will apply to each of the FI subprojects; ・ In appraising a proposed FI operation, the Bank reviews the adequacy of country
(b) Where Bank support is provided to the FI for a general purpose, the environmental requirements relevant to the project and the proposed EA
requirements of this ESS will apply to the entire portfolio of the FI’s future arrangements for subprojects, including the mechanisms and responsibilities for
subprojects from the date on which the legal agreement becomes effective. (para.5) environmental screening and review of EA results. When necessary, the Bank
・ The FI will comply with any exclusions in the legal agreement and apply relevant ensures that the project includes components to strengthen such EA arrangements.
national law for all FI subprojects. In addition, the FI will apply the relevant For FI operations expected to have Category A subprojects, prior to the Bank's
requirements of the ESSs to any FI subproject that involves resettlement (unless the appraisal each identified participating FI provides to the Bank a written
risks or impacts of such resettlement are minor), adverse risks or impacts on assessment of the institutional mechanisms (including, as necessary, identification
Indigenous Peoples or significant risks or impacts on the environment, community of measures to strengthen capacity) for its subproject EA work. If the Bank is not
health and safety, labor and working conditions, biodiversity or cultural heritage. satisfied that adequate capacity exists for carrying out EA, all Category A
(para.11) subprojects and, as appropriate, Category B subprojects – including EA reports –
・ FIs are required to develop and maintain, in the form of an ESMS, effective are subject to prior review and approval by the Bank. (para.11)
environmental and social systems, procedures and capacity for assessing,
managing, and monitoring risks and impacts of subprojects, as well as managing
overall portfolio risk in a responsible manner. (para.3) The ESMS consists of
environmental and social policy, environmental and social procedures (e.g.
categorization, impact assessment, monitoring), organizational capacity and
competency, and monitoring and reporting. (para.3, para.14-23)
21 Stakeholder <ESS10 Stakeholder Engagement and Information Disclosure> <OP4.01> ・ Reference to SEP (the
Engagement ・ ESS10 applies to all projects supported by the Bank through Investment Project ・ For all Category A and B projects proposed for IBRD or IDA financing, during definition of stakeholders,
Plan, Financing. (para.4) the EA process, the borrower consults project-affected groups and local stakeholder analysis,
Stakeholder ・ “Stakeholder” refers to individuals or groups who: (a) are affected or likely to be nongovernmental organizations (NGOs) about the project's environmental aspects preparation and
Analysis affected by the project (project-affected parties); and (b) may have an interest in and takes their views into account. The borrower initiates such consultations as implementation of the
the project (other interested parties). (para.5) early as possible. For Category A projects, the borrower consults these groups at stakeholder engagement plan,
・ The Borrower will develop and implement a Stakeholder Engagement Plan (SEP) least twice: (a) shortly after environmental screening and before the terms of and meaningful consultation
(…) A draft of the SEP will be disclosed as early as possible, and before project reference for the EA are finalized; and (b) once a draft EA report is prepared. In and grievance redress
appraisal. (para.13) The SEP includes identification of stakeholders and proposal addition, the borrower consults with such groups throughout project mechanism planned for the
for future engagement. (para.13) implementation as necessary to address EA-related issues that affect them. entire project cycle)
・ The Borrower will undertake a process of meaningful consultation in a manner (para.14)
that provides stakeholders with opportunities to express their views on project ・ No OPs specify definition of stakeholder, stakeholder analysis and SEP.
risks, impacts, and mitigation measures, and allows the Borrower to consider and ・ No OPs specify meaningful consultation and a GRM for whole a project cycle.

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Major Changes
(Unless otherwise specified, the
No Area New SGPs (ESF/ESS)1) Previous SGPs(OP)2) changes are new, additional
requirements under the new
ESF/ESS.)
respond to them. (para.21)
・ Meaningful consultation is a two-way process. (para.22)
・ The Borrower will propose and implement a grievance mechanism to receive and
facilitate resolution of such concerns and grievances. (para.26)
・ The grievance mechanism may include the following:
(a) Different ways in which users can submit their grievances
(b) A log where grievances are registered in writing and maintained as a database
(c) Publicly advertised procedures
(d) Transparency about the grievance procedure
(e) An appeals process (including the national judiciary) to which unsatisfied
grievances may be referred when resolution of grievance has not been achieved.
(Annex 1 para1-3)
Source:
1) WB ESF: https://www.worldbank.org/en/projects-operations/environmental-and-social-framework
2) WB OPs related to Environmental and Social Safeguards: https://policies.worldbank.org/sites/ppf3/Pages/Manuals/Operational%20Manual.aspx

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3.3.3 Policies of MDBs on Specific Safeguards Topics

The Use of Common Approach

Under the current GL, JICA is co-financing about 10 projects each year with other MDBs. This
section reviews the policies of the WB, ADB and IFC in terms of conditions of using the common
approach when co-financing a project, and actual procedures when the common approach is adopted.

1) The WB
The text related to common approach in the WB’s ESF is shown below.

Where the Bank is jointly financing a project with other multilateral or bilateral funding agencies, the
Bank will cooperate with such agencies and the Borrower in order to agree on a common approach
for the assessment and management of environmental and social risks and impacts of the project. A
common approach will be acceptable to the Bank, provided that such approach will enable the project
to achieve objectives materially consistent with the ESSs. The Bank will require the Borrower to
apply the common approach to the project. The Bank will also coordinate with such agencies so that
the Bank and the Borrower may be able to disclose one set of project-related materials for stakeholder
engagement.

The World Bank Environmental and Social Policy for Investment Project Financing, p5, para 9
World Bank ESF (2018)

As above, the WB may use the common approach on the condition that it will achieve safeguards-
related objectives materially consistent with the ESSs. However, the specific details in terms of how
the project as a whole including components financed by other MDBs will be reviewed, monitored
or how procedures related to preparation and disclosure of safeguards documents are not articulated
in the ESF. At the time of preparation of this report, no project that applies the common approach
as per the ESF has been identified.

2) ADB
SPS (2009) states that ADB “will make efforts to collaborate with the borrower/client and
cofinanciers to adopt a single social and environmental assessment and planning process and unified
safeguard documentation, consultation, and disclosure requirements to satisfy the safeguard
principles and requirements of ADB and the cofinanciers”(SPS, para.70).

Some bilateral donors have a policy to use MDB’s safeguards policy when jointly financing projects
with such MDBs. AusAID’s policy, for example, states that “the Department of Foreign Affairs and
Trade (DFAT) promotes harmonization of policies among donors to reduce the burden of
multiple donor requirements on partner governments. DFAT’s key multilateral partners have

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their own environmental and social safeguard systems, which are broadly consistent with this
policy. The safeguards systems of these partners can generally be accepted when they are
implementing an investment supported by DFAT.” 1 In such cases, ADB’s SPS is applied and
ADB will take primary responsibility to ensure that the safeguards requirements are adhered to.
Agence Française de Developpement (AFD), meanwhile, makes every effort to agree on a common
approach for the assessment and management of the project’s environmental and social risks with
the cofinancier(s) in order to avoid excessive environmental and social due diligence and “if AFD
is not the coordinator of the financing, AFD assesses the environmental and social documents
produced under the responsibility of the client and/or lead funder” (para.7-8, AFD Environmental
and Social Risk Management Policy). For example, in Greater Colombo Water and Wastewater
Management Improvement Investment Program - Tranche 3, a project co-financed by ADB and
AFD, SPS was used to prepare IEE and RAP.
In 2008, ADB signed Framework Cofinancing Agreement (FCA) with Islamic Development Bank
(IDB). ADB also developed ADB–IDB Partnership and Cofinancing Guide in 2016. The Guide
states “Projects cofinanced under the FCA must comply with ADB’s and IDB’s prevailing social
and environmental safeguard requirements” and “ADB, IDB, and the borrower collaborate to meet
the prerequisites, through early consultation and agreement on a common approach to addressing
environmental and social risks. Partners apply their respective accountability policies, specifically
those relating to anticorruption and integrity measures” (p.11). In practice, ADB and IDB jointly
develop a project through information sharing and coordination, which include harmonizing the
schedule of the mission. Regarding safeguard, however, it is required that both ADB and IDB’s
requirements be met and thus falls short of harmonizing the process and adopting a common
approach. As of 2017, ADB have co-financing agreements with 12 agencies, including Partnership
for Quality Infrastructure with JICA. More recently, ADB and the Republic of Korea signed a
memorandum of understanding to expand Korea’s cofinancing support for ADB projects in Asia
and the Pacific 2.

3) IFC
IFC’s Sustainability Policy and PS do not include reference to common approach.

MDBs’ Policies on Disclosure of Safeguards Documents

1) Disclosure of Safeguards Documentation


The Environmental and Social Policy of the WB states that the Bank will “disclose documentation
relating to the environmental and social risks and impacts of High Risk and Substantial Risk projects
prior to project appraisal. (para 51)”. There is no requirement related to the duration of disclosure.
Also, the documents such as EIA do not have to be the final version as long as these documents

1
Environmental and Social Safeguard Policy (Updated March 2019), p. 21, Australian Aid, https://dfat.gov.au/about-
us/publications/Documents/environmental-social-safeguard-policy.pdf
2
ADB Signs Agreements with the Republic of Korea to Strengthen Cofinancing and Technical Cooperation (3 May 2018),
https://www.adb.org/news/adb-signs-agreements-republic-korea-strengthen-cofinancing-and-technical-cooperation

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“provide sufficient detail to inform stakeholder engagement and Bank decision making (para.51)”.
Once the draft documentation is finalized or updated, it will be disclosed.

Meanwhile, disclosure of draft environmental impact assessment reports of Category A projects for
at least 120 days before Board consideration is required under ADB’s SPS (para.53). IFC does not
require disclosure of EIA reports, but Environmental and Social Review Summary (ESRS), a
document prepared by the IFC, has to be disclosed in the IFC website prior to IFC’s Board of
Directors/Management consideration of the investment. The required disclosure period is 60 days
for Category A projects and 30 days for Category B and C projects. (para.4.2.6, IFC Environmental
and Social Review Procedures Manual, October 2016)

2) Disclosure of Monitoring and Supervision Reports


There is no formal requirement about the disclosure of environmental and social monitoring reports
in SGPs and policies on information disclosure of the WB, EBRD, IBD and AfDB. ADB, on the
other hand, requires that the environmental monitoring report be disclosed on ADB’s website
(para.17, Appendix 1, SPS). Apart from that, the aide-mémoire of operational missions is made
publicly available if both the WB and the country/borrower agrees. (para.3a, Access to Information
Directive/Procedure, revised April 2019)

3.4 Changes in Surroundings related to the Review of JICA GL for Environmental


and Social Considerations and its Process

3.4.1 Ruggie Principles (Guiding Principles on Business and Human Rights: Implementing the
United Nations “Protect, Respect and Remedy” Framework)

In 2008, “Protect, Respect and Remedy” Framework was submitted to the UN Human Rights
Council by Mr. John Ruggie who was assigned as the Special Representative of the Secretary-
General on the issue of human rights and transnational corporations and other business enterprises
in 2005. The framework was called “Ruggie Framework” and rests on 3 pillars, namely “the State
duty to protect against human rights abuses by third parties, including business enterprises,” “the
corporate responsibility to respect human rights,” and “access to remedy.” To implement the
framework, the Guiding Principles on Business and Human Rights: Implementing the United
Nations “Protect, Respect and Remedy” Framework (hereafter called “Guiding Principles”) was
developed and unanimously welcomed by the Council.

The government of Japan has made a commitment to implement the Guiding Principles and
announced to develop the national action plan for business and human rights at the UN Forum on
Business and Human Rights in November 2016. According to MOFA of Japan, it is expected that
the national action plan is to be disclosed in mid-2020.

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3.4.2 SGPs of WB, ADB and IFC as the standards and Good Practices to be referred

With reference to Section 2.6 of JICA GL, the referenceable standards and good practices of the
SGPs of WB, ADB and IFC are reviewed and summarized as the reference. SGPs of ADB and IFC
are described separately in Section 3.3.1.

WBG’s sector wise EHSGs.

EHSG consists of the General EHSGs and the Industry Sector Guidelines which are designed to be
used together. Since the Industry Sector Guidelines indicate sector-specific potential environmental
and social impacts and indicators/standards for environmental and social considerations, it is easier
for project proponents etc. or EIA approving agency to confirm the sector specific survey parameters
and required considerations.

Currently, there are 8 sectors which have the sector-wise guidelines are available on the official
website, namely agribusiness/food production, chemicals, forestry, general manufacturing,
infrastructure, mining, oil and gas, and power, and under each sector, there are several project
specific guidelines. For example, the mining EHSGs describe more specific impact on underground
water and health, safety and environment of tailing dams, and the infrastructure EHSGs (for
railways) discuss maintenance of rolling stocks, which are more specific and details than the
descriptions of the general EHSGs.

MDBs’ application of the EHSGs are summarized as follows:


WB: “The project will apply the relevant requirements of the [EHSGs]. When host country
requirements differ from the levels and measures presented in the EHSGs, the Borrower will be
required to achieve or implement whichever is more stringent. If less stringent levels or measures
than those provided in the EHSGs are appropriate in view of the Borrower’s limited technical or
financial constraints or other specific project circumstances, the Borrower will provide full and
detailed justification for any proposed alternatives through the environmental and social assessment.
This justification must demonstrate, to the satisfaction of the Bank, that the choice of any alternative
performance level is consistent with the objectives of the ESSs and the applicable EHSGs, and is
unlikely to result in any significant environmental or social harm.”(ESS 1, para18)

ADB: ADB SPS refers to EHSGs as an example of the internationally recognized standards in
Appendix 1 for “9. Pollution Prevention and Abatement” (para 33, SPS) and “10. Health and Safety”
(para 41, SPS).

IFC: IFC PS states that the EHSGs are a technical source of information during project appraisal;
the performance levels and measures of the EHSGs are generally considered to be achievable in
new facilities at reasonable costs by existing technology; for IFC-financed projects, it may involve
the establishment of site-specific targets with an appropriate timetable for achieving them; and in
case that less stringent levels or measures are appropriate for the project, a full and detailed
justification for any proposed alternatives is required to describe in an EIA Report (para 6, 7,

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Environmental and Social Sustainability, PS).

Equator Principles 3 (EP3):

EP3 requires compliance with IFC’s PS and EHSG in addition to the national legislations and
clearance of environmental and social safeguards for the project in Non-Designated Countries. If it
is in the designated countries, the national legislations and clearance need to be complied (p. 6, EP).

3.4.3 Quantification of Environmental and Social Costs and Benefits in Japan and MDBs’ Projects

Quantification of environmental and social costs and benefits is described in Appendix of JICA GL.
Various examples of the quantification in Japan and MDBs are summarized as follows.

Japan: According to “The Basic Matters relating to the Guidelines etc. to be Established by the
Competent Minister in Accordance with the Provisions of the EIA Act (The Environment Agency
Notification No.87 of December 12, 1997),”there is no requirement for quantification of the costs
and benefits for the EIA.

MDBs’ Practices:

The practices of quantification of costs and benefits for the EIA are summarized below according
to each SGP.

(1) WB: ESF describes “For each of the alternatives, quantifies the environmental and social impacts
to the extent possible, and attaches economic values where feasible.” in (g) Analysis of Alternatives,
Annex 1-D, ESS 1.

(2) ADB: in SPS, para 4 under “D. Requirement, Safeguard Requirements 1: Environment” of SPS
describes “The rationale for selecting the particular project location, design, technology, and
components will be properly documented, including, cost-benefit analysis, taking environmental
costs and benefits of the various alternatives considered into account. The “no project” alternative
will be also considered.” However, it does not specify the quantification for costs and benefits.
(3) IFC: Para 61 of IFC GN states “The client should consider economic, financial, environmental
and social costs and benefits and identify to which parties these accrue.” However, there is no
requirement for quantitative evaluation of the environmental and social cost and benefits in the PS
nor GN.

JICA: The costs of land acquisition, environmental management plan, environmental and social
monitoring reports are all included in the project cost for JICA projects. Additionally, as for the
environmental and social costs and benefits of JICA’s projects including the reviewed projects, the
GHG emission or reduction was included as the costs or benefit when Economic Internal Rate of
Return (EIRR) is calculated in economic analysis since the market value is available for GHG
emission especially for the large scale power generation projects which GHG emission is relatively
large. For instance, No.1 Navoi Thermal Power Station Modernization Project which replaced the

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existing obsolete power plant with a highly-efficiency Gas Combined Cycle Cogeneration Power
Plant (CCPP) calculated the economic benefit of GHG emission reduction using the average spot
rate for the certified emission reduction (CER) of Blue Next, a European environmental trading
exchange and was considered the largest CO2 permit spot market. Another example is Shahid
Rajaee Power Plant Construction Project, a project to construct high-efficiency gas turbine
combined cycle power generation units in Qazvin Province, Iran. It has also calculated the benefit
of GHG emission reduction using the trading price of the European Union Emission Trading
Scheme (EU ETS).

WB: When the costs and benefits of GHG emission or reduction was included, it is suggested that
the benefits and costs are quantified with the shadow price based on “Shadow price of carbon in
economic analysis Guidance Note” (para 2, Applicability, Shadow price of carbon in economic
analysis Guidance Note, 2017).

ADB: ADB uses the same rate for all the projects for the economic value of the GHG emission by
referring to the IPCC report (para160, 161, Guidelines for the Economic Analysis of Projects, ADB).

3.4.4 Alternative Considerations Especially for “Without Project Scenario”

MDBs’ SGP and Japanese legislation on alternative considerations at the SEA and EIA stages were
reviewed and summarized below. As for the JICA GL, there is no specific description on alternative
considerations at each stage of SEA and EIA and on whether “without project scenario” includes
the zero option as part of such scenario.

MDB

SEA Stage

The SGPs of WB or ADB do not specify requirements on alternative considerations for SEA.

EIA Stage

WB ESS1, ADB SPS and IFC PS describe alternative considerations as follows:

WB: “(g) Analysis of Alternatives

• Systematically compares feasible alternatives to the proposed project site, technology, design, and
operation—including the “without project” situation—in terms of their potential environmental and
social impacts.

• Assesses the alternatives’ feasibility of mitigating the environmental and social impacts; the capital
and recurrent costs of alternative mitigation measures, and their suitability under local conditions;
and the institutional, training, and monitoring requirements for the alternative mitigation measures.
• For each of the alternatives, quantifies the environmental and social impacts to the extent possible,
and attaches economic values where feasible.” (para 13 (g), Annex 1.D, ESS1)

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ADB: “Examine alternatives to the project’s location, design, technology, and components and their
potential environmental and social impacts and document the rationale for selecting the particular
alternative proposed. Also consider the no project alternative.” (Policy Principle 3, 1. Environmental
Safeguards, SPS)
“This section examines alternatives to the proposed project site, technology, design, and
operation—including the no project alternative— in terms of their potential environmental impacts;
the feasibility of mitigating these impacts; their capital and recurrent costs; their suitability under
local conditions; and their institutional, training, and monitoring requirements. It also states the basis
for selecting the particular project design proposed and, justifies recommended emission levels and
approaches to pollution prevention and abatement.” (F. Analysis of Alternative, Annex to Appendix
1: Outline of an Environmental Impact Assessment Report)

IFC: “For greenfield developments or large expansions with specifically identified physical
elements, aspects, and facilities that are likely to generate potential significant environmental or
social impacts, the client will conduct a comprehensive Environmental and Social Impact
Assessment…”(footnote 11, PS1)
“For greenfield developments, the ESIA includes an examination of technically and financially
feasible alternatives…” (GN 25)

Japan

In Japan, according to “the Basic Matters relating to the Guidelines etc. to be Established by the
Competent Minister in Accordance with the Provisions of the EIA Act (The Environment Agency
Notification No.87 of December 12, 1997),” “without project scenario” needs to be included in
alternative considerations at scoping stage (hairyosho preparation stage) 1 . Moreover, “without
project scenario” includes “zero option” which is defined as the alternative option in which the same
project purpose is feasible without the project which is subject to EIA and also considered as one of
the alternative considerations2.

1
The Guidelines for the Introduction of Strategic Environmental Assessment (MOEJ, 5 April 2007) targets the projects
which are likely to be large scale and have significant impacts, especially Class-1 projects specified by EIA Act of Japan (13
June 1997) and which project location and project scale are not finalized but in the planning stage. Additionally, the EIA
Network website of MoEJ defines that Hairyosho is the document which describes examination results of alternatives for the
project location and scale in a planning stage for environmental conservation (http://assess.env.go.jp/1_seido/1-1_guide/3-
1.html).
2
According to “The Basic Matters relating to the Guidelines etc. to be Established by the Competent Minister in
Accordance with the Provisions of the Environmental Impact Assessment Act (The Environment Agency Notification No.87
of December 12, 1997),”.
1.1 (3) In examining the items for Primary Environmental Impact Consideration, as a general rule, appropriate multiple plans
concerning location and scale, or structure and placement of building etc. pertaining to Class-1 project (hereinafter referred
to as the "multiple plans concerning location etc.") shall be prepared, and in the case where such multiple plans concerning
location etc. are not prepared, the reason thereof shall be clarified.
1.3 (3) A statement to the effect that efforts must be made to include an option of not implementing the said project, to the
extent that it is feasible, in the multiple plans concerning location etc., shall be specified in the Guidelines for the Selection
of the Items for Primary Environmental Impact Consideration etc.

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In the EIA stage of an individual project, alternative considerations are required (1) “concerning a
wide range of environmental conservation measures including those related to structure and location
of buildings, environmental conservation facilities, and construction method, etc.” at the scoping
stage” (4.5.(3) A), and (2) “adequacy of the environmental conservation measures which are being
considered for adoption shall be verified through means such as comparative examination of
multiple proposals” at the draft final EIA stage, (5.2.(5)) of the “Basic Matters relating to the
Guidelines etc. to be Established by the Competent Minister in Accordance with the Provisions of
the EIA Act (The Environment Agency Notification No.87 of December 12, 1997)”.

“Without Project Scenario”

Although the ESIA of WB funded projects have alternative considerations including “without
project” (no project at all), the case which does not have the proposed project but with other
measures to achieve the same proposed project objective is not considered unlike “without project
scenario” defined in the Basic Matters relating to the Guidelines etc. to be Established by the
Competent Minister in Accordance with the Provisions of the EIA Act of Japan (The Environment
Agency Notification No.87 of December 12, 1997). As for ADB funded projects, the ESIA also
considers a “without project” alternative; however, the case without the proposed project but with
other measures to achieve the same proposed project objective is not considered.

3.4.5 Natural Disaster aspect in the EIA for Projects in Japan and Funded in MDBs

Basic Act on Disaster Management of Japan defines that disaster “means damage resulting from a
storm, tornado, heavy rainfall, heavy snowfall, flood, slope failure, mudflow, high tide, earthquake,
tsunami, eruption, landslide, or other abnormal natural phenomena, or a large fire or explosion or
other causes provided for by Cabinet Order and similar to the above in the extent of damage they
cause” (Article 2.1)

Additionally, during the working group meeting for reexamination of JICA GL Operation, it was
suggested to differentiate the definition of “disasters” and “accidents”, so far there is no clear
definition of “accidents” in the Basic Matters relating to the Guidelines etc. to be Established by the
Competent Minister in Accordance with the Provisions of the EIA Act of Japan (The Environment
Agency Notification No.87 of December 12, 1997). As for WB ESF and IFC PS, there is also no
clear requirements in the ESIA separately for “disasters” and “accidents”. For instance, WB ESS4
describes emergency events arising from both natural and man-made hazards, such as fire,
explosions, leaks or spills, which may occur for a variety of different reasons, including failure to
implement operating procedures that are designed to prevent their occurrence, extreme weather or
lack of early warning.

Handling of the Disaster aspect in Japanese Environmental Impact Assessment Act

The “Basic Matters” relating to the Guidelines etc. to be Established by the Competent Minister in

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Accordance with the Provisions of the EIA Act (The Environment Agency Notification No.87 of
December 12, 1997) are the matters that should be basic across the board regardless of the type of
the project, related to standards and guidelines for each type of project to be set by the competent
ministry. In Appendix of “Basic Matters”, a table showing category of environmental components
are shown. In the table, disasters (both natural disasters and accidents) are not listed.
Table 3-11 Category of Environmental Component Shown in the “Basic Matter”
Category of Effect Construction Presence・Service
Factor
Category of Environmental Component Subcategory

Subcategory
Maintenance of Air Ambient air
Sound Condition Environment quality
of Natural
Components of Noise,
the Environment infrasound
Vibration
Offensive
odor
Other
Water
Environment Water quality

Sediment

Ground water

Other
Soil Landform,
Environment geology
and Other
Environment Ground

Soil

Other
Ensuring
Biodiversity and Flora
Systematic
Conservation of Fauna
Natural
Environment
Ecosystem
Beneficial
Contact between Landscape
People and
Nature
Places for activities with nature
Environmental loads
Waste etc.

Greenhouse
gas etc.
Radioactive materials in general Radiation
environment quantity
Source:Environmental Impact Assessment Network, MOEJ website
(http://assess.env.go.jp/files/1_seido/1-3_horei/honbun260627-1.pdf)

The competent ministry of each target sector sets the subcategories of the environmental

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components which are likely to be impacted by the target sector’s characteristics based on the above-
mentioned components. The ministry also issues the ministerial ordinance and technical guidelines
on a specific methodology for EIA for each target sector. In practice, it is suggested to consider land
stability changed by development (e.g. liquefaction, ground deformation such as subsidence and
landslides, and increased risk of slope failure, etc.) as environmental impact items for the EIA in
“EIA Technical Guide – Ambient Air, Water, Soil and Environmental Impact (2017, Japanese
Ministry of Environment)”.

Examples of EIA based on Japanese EIA Act Which Dealt with Natural Disasters

As of May 2019, 3 examples 1 which dealt with natural disasters were found as shown in the table
below, by searching on the internet including “Environmental Impact Assessment Network”
managed by Ministry of Environment, Japan. However, it should be noted that regarding Project
No.1 and 2, the contents of each EIA document are different from the current EIA contents since the
EIA Act was not fully applied at that time and the transitional measure was applied for these projects,
although these EIA documents were published after enforcement of the Act.

Table 3-12 Projects that have Selected Parameters related to Natural Disaster in their EIA under the
Japanese EIA Act
No. Selected Parameters related to Natural Disasters Project Name
1 Landform, Impact on stability of land, Urban development project for housing in south
geology change of sediment discharge east district, Seto city
amount, change of current
landform
2 Landform, surface Degree of change of Shitou first specified land readjustment project in
geology, soil, landform, stability of slope, Ichihara city planning project
unique natural preservation of surface soil
phenomenon
3 Landform and Stability of land Linear Chuo Shinkansen (between Tokyo and
geology Nagoya city)
Source: 1, 2: Website of Environmental Impact Assessment Network, MOEJ
http://assess.env.go.jp/2_jirei/index.html
3: Website of Central Japan Railway Company
https://company.jr-central.co.jp/chuoshinkansen/assessment/document1408/nagano/

Projects No.1 and 2 of Table 3-12 are area development projects and No.3 is a linear development
project. In these EIAs, disasters related parameters, such as landslide and slope failure induced by
instability of slope and banking, were selected because the projects involved a large scale land
forming and slope construction works. As an example, the impact assessment and mitigation
measures of stability of land for Project No.3 is summarized below as EIA document was disclosed

1
EIA reports prepared under the Japanese Environmental Impact Assessment Act are partially available on the website,
which mainly includes the EIA reports which are currently disclosed.

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on the website of project proponents etc.

“EIA of Linear Chuo Shinkansen (between Tokyo and Nagoya city) (Nagano prefecture)” was
prepared for Project No. 3 in August 2014. In the scoping of the EIA, “Stability of Land” was
selected under the environmental component category of “Landform and Geology,” by considering
the construction work of tunneling, cutting and removal of existing structures. As the environmental
mitigation measures for a land stability, “applying appropriate design and construction method,”
“protection of slopes” and “appropriate management of construction” were proposed in the EIA as
shown in the following box. The EIA, however, does not include any impact assessments on natural
disaster-related parameters for the operation phase.

<Applying appropriate design and construction method>


Table 8-3-2-9(1) Content of environmental mitigation measure
Implementing organization Central Japan Railway Company
Details of Type, method Applying appropriate design and construction method
implementation Location, area Changes to be made by construction works
Time, period Design phase and construction phase
Effect of environmental mitigation measure Applying construction plan to secure land stability by
grasping details of the property of the area based on detail
survey of landform, geology, etc. prior to construction work
and thus, impact on stability of land can be avoided.
Uncertainty N/A
Impact on other environmental aspects N/A

<Protection of slopes>
Table 8-3-2-9(2) Content of environmental mitigation measure
Implementing organization Central Japan Railway Company
Details of Type, method Protection of slopes
implementation Location, area Areas to be applied earth cutting
Time, period Construction phase
Effect of environmental mitigation measure For slopes and slant, appropriate protection method such as
retaining wall, concrete spraying and ground anchoring, etc.
will be applied depending on the condition. For rock lump
with a potential rock fall, appropriate protection method such
as removal works and rock fall prevention works, etc. will be
applied. Then, collapse of slope and slant will be prevented
and thus, impact on stability of land can be avoided.
Greening is also considered, and planting works will be
implemented as much as possible.
Uncertainty N/A
Impact on other environmental aspects N/A

<Appropriate management of construction>


Table 8-3-2-9(3) Content of environmental mitigation measure
Implementing organization Central Japan Railway Company
Details of Type, method Appropriate management of construction
implementation Location, area Changes to be made by construction works
Time, period Construction phase
Effect of environmental mitigation measure During excavation, embankment and cutting works,

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construction management will be conducted with attention to


landform, geology and groundwater condition, construction
work having high safety will be realized and thus, impact on
stability of land can be avoided.
Uncertainty N/A
Impact on other environmental aspects N/A
Source: Website of Central Japan Railway Company
https://company.jr-central.co.jp/chuoshinkansen/assessment/document1408/nagano/_pdf/eis2_naganoh08-03-02.pdf

WB’s Practice for Disasters

WB ESS4 specifies impacts of disasters in the following sections:

“The Borrower will design, construct, operate, and decommission the structural elements of the
project in accordance with national legal requirements, the EHSGs and other GIIP, taking into
consideration safety risks to third parties and affected communities. Structural elements of a project
will be designed and constructed by competent professionals, and certified or approved by
competent authorities or professionals” (para 6, ESS 4).

ESS4 also requires the borrowers that “[t]he types of measures that can be incorporated to reflect
climate change considerations and other risk conditions such as flooding are discussed in more detail
in the EHSGs and GIIP” (ESS4 GN6.4).

Additionally, ESS4 requires the borrowers to consider the incremental risks of the public’s potential
exposure to operational accidents or natural hazards, including extreme weather events, where the
project includes new buildings and structures that will be accessed by members of the public. (para7,
ESS4).

3.4.6 Climate Change issue in the ESIA under MDBs’ SGP

Impact assessment of climate change in the ESIA under MDBs’ SGP was reviewed as a reference
for Appendix “Scope of Impacts to Be Assessed” of JICA GL in Table 3-13. There is no SGP which
mention any specific requirements to contribute to the Paris Agreement (2°C goal). However,
prediction and quantification of GHG emission and alternative consideration for GHG emission
reduction which are technically and financially feasible are discussed in the SGP as summarized in
Table 3-14.

Table 3-13 Requirements on GHG Emission


WB ADB IFC
Scope of “As part of the environmental and The threshold to quantify “For projects that are
Prediction and social assessment of the project, the GHG emission “is expected to or currently
Quantification of “the Borrower will characterize generally 100,000 tons of produce more than 25,000
GHG Emission and estimate sources of air carbon dioxide equivalent tonnes of CO2-equivalent
pollution related to the project. per year for the aggregate annually, the client will
This will include an estimate of emissions of direct sources* quantify direct
gross GHG emissions resulting and indirect sources* emissions…”(para8, PS3)。
from the project…” except the associated with electricity “Clients with projects

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WB ADB IFC
following cases. (para 16) purchased for own producing significant GHG
・For projects that have diverse consumption.” emissions are required to
and small sources of emissions (SPS Appendix 1, footnote evaluate (i) Scope 1
(for example, community-driven 10) Emissions and (ii) Scope 2
development projects); and Emissions.” (GN3, Annex
・where emissions are not likely A)
to be significant (for example,
projects in education and social
protection) (para 16)
“To avoid double counting, gross
GHG emissions are calculated
only for direct GHG emissions
(scope 1*)” (GN 16.1)
Threshold for None Generally, 100,000 tons of More than 25,000 tonnes of
GHG Emission carbon dioxide equivalent CO2-equivalent annually as
Calculation per year for the aggregate above-mentioned (para 8,
emissions as above- PS3)
mentioned (SPS Appendix
1, footnote 10)
Frequency of Expected 1 time when the ESIA is Annually & quantitatively Annually & quantitatively
GHG Emission prepared. (para 16, ESS 3) (para 39, SPS) (para 8, PS3)
Calculation
Information To be disclosed as a part of ESIA To be disclosed as a part of “[C]lients are encouraged to
Disclosure depending on the risk ESIA disclose their GHG
classification emissions annually through
corporate reports, or through
other voluntary disclosure
mechanisms currently being
used by private sector
companies internationally”
(para 19, GN3)
Note: (i) Scope 1 Emissions: direct emissions from the facilities that they own or control within the physical project boundary and, if feasible
and relevant, and (ii) Scope 2 Emissions: indirect emissions associated with the project’s use of energy but occurring outside the project
boundary (e.g., GHG emissions from purchased electricity, heat or cooling). (Annex A, IFC PS GN 3)
Source: Prepared by JICA Study Team based on respective MDBs’ SGP

As for the EP3, requirements regarding quantification of GHG emission are stipulated as s below:

“Quantification of GHG emissions will be conducted by the client in accordance with internationally
recognised methodologies and good practice, for example, the GHG Protocol. The client will
quantify Scope 1 and Scope 2 Emissions.”

The Equator Principles Financial Institutions (EPFI) will require the client to report publicly on an
annual basis on GHG emission levels (combined Scope 1 and Scope 2 Emissions) during the
operational phase for Projects emitting over 100,000 tonnes of CO2 equivalent annually. Clients
will be encouraged to report publicly on Projects emitting over 25,000 tonnes. Public reporting
requirements can be satisfied via regulatory requirements for reporting or environmental impact
assessments, or voluntary reporting mechanisms such as the Carbon Disclosure Project where such
reporting includes emissions at Project level.”(EP 3, p.12)

Current JICA GL also regard the impact of climate change as the scope of impacts to be assessed,
and the Climate Finance Impact Tool for Mitigation, so called “the JICA Climate-Fit (Mitigation)”
is used as a methodology to evaluate the GHG emission reduction from the baseline scenario.

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Alternative considerations for GHG emission reduction which are technically and financially
feasible are discussed in the SGP of WB and IFC. As shown in Table 3-14, WB ESS 3 mentions it
as the project-related air emission, while IFC PS 3 specifically states as project-related GHG
emissions. Such description was not found in ADB SPS.

Table 3-14 Analysis of Alternative Considerations on GHG Emission Reduction which is Technically
and Financially Feasible and Cost Effective
WB IFC ADB
“In addition to the resource “In addition to the resource N/A
efficiency measures described efficiency measures described
above, the Borrower will consider above, the client will consider
alternatives and implement alternatives and implement
technically and financially feasible technically and financially feasible
and cost-effective options to avoid and cost-effective options to
or minimize project-related air reduce project-related GHG
emissions during the design, emissions during the design and
construction and operation of the operation of the project.” (para 7,
project.” (para 15, ESS 3) PS 3)

3.4.7 Indivisible Projects, Derivative and Secondary Impact and Cumulative Impact under MDBs’
SGP

Impact assessment of the associated facility, indirect impact and cumulative impact in the ESIA
under MDBs’ SGP was reviewed as a reference for Appendix “Scope of Impacts to Be Assessed”
of JICA GL 1. As for the impact caused by persons’ actions, such an impact is included in the
cumulative impact under regulations of US Council on Environmental Quality, though SGPs of WB,
ADB and IFC do not include them in the definition of the cumulative impact.

Table 3-15 Definition of Associated Facility under MDBs’ SGP


Organization Definition Requirements
WB “Associated Facilities” means “facilities or The environmental and social assessment will also
activities that are not funded as part of the identify and assess, to the extent appropriate, the
project and, in the judgment of the Bank, are: (a) potential environmental and social risks and
directly and significantly related to the project; impacts of Associated Facilities. The Borrower will
and (b) carried out, or planned to be carried out, address the risks and impacts of Associated
contemporaneously with the project; and (c) Facilities in a manner proportionate to its control
necessary for the project to be viable and would or influence over the Associated Facilities. To the
not have been constructed, expanded or extent that the Borrower cannot control or
conducted if the project did not exist”. (para 11, influence the Associated Activities to meet the
ESS 1) requirements of the ESSs, the environmental and
social assessment will also
identify the risks and impacts the Associated
Facilities may present to the project. (para 32,
ESS1)
ADB Associated facilities are facilities that are “not The impact of the associated facility is included in
funded as part of the project (funding may be the scope of the project impact and risks. However,
provided separately by the borrower/client or by potential impacts that might occur without the
third parties), and whose viability and existence project or independently of the project are not
depend exclusively on the project and whose included.
goods or services are essential for successful In general, SPS also requires that “Environmental

1
The English terminology used here is the one adopted by MDBs for “indivisible projects” as well as “derivative and
secondary impacts” under JICA GL.

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Organization Definition Requirements


operation of the project”(para 6, Appendix 1, impacts and risks will also be analyzed for all
SPS) relevant stages of the project cycle, including
preconstruction, construction, operations,
decommissioning, and postclosure activities such
as rehabilitation or restoration”.
(para 6, Appendix 1, SPS)
IFC Associated facilities, are “facilities that are not The impact of the associated facility is included in
funded as part of the project and that would not the scope of the project impact and risks (para 8,
have been constructed or expanded if the project PS1)
did not exist and without which the project would
not be viable”. (para 8, PS1)
Source: Prepared by JICA Study Team.

Table 3-16 Definition of Indirect Impact/Secondary Impact under MDBs’ SGP


Organization Definition
WB An indirect impact is an impact which is caused by the project and is later in time or farther removed in
distance than a direct impact, but is still reasonably foreseeable, and will not include induced impacts 1。
. (footnote 21, ESS1)
ADB At an early stage of project preparation, the borrower/client will identify potential direct, indirect,
cumulative and induced environmental impacts on and risks to physical, biological, socioeconomic, and
physical cultural resources and determine their significance and scope, in consultation with stakeholders,
including affected people and concerned NGOs. (para 4, Appendix 1, SPS)
IFC [I]impacts from unplanned but predictable developments caused by the project that may occur later or at
a different location; or (iii) indirect project impacts on biodiversity or on ecosystem services upon which
Affected Communities’ livelihoods are dependent. (para8, PS1)
Source: Prepared by JICA Study Team based on the respective SGP

Table 3-17 Definition of Cumulative Impact under MDBs’ SGP


Organization Definition
WB The cumulative impact of the project is the incremental impact of the project when added to impacts from
other relevant past, present and reasonably foreseeable developments as well as unplanned but predictable
activities enabled by the project that may occur later or at a different location. Cumulative impacts can
result from individually minor but collectively significant activities taking place over a period of time. The
environmental and social assessment will consider cumulative impacts that are recognized as important on
the basis of scientific concerns and/or reflect the concerns of project-affected parties. The potential
cumulative impacts will be determined as early as possible, ideally as part of project scoping. (Footnote
22, ESS1)
ADB (iii) areas and communities potentially affected by cumulative impacts from further planned development
of the project, other sources of similar impacts in the geographical area, any existing project or condition,
and other project-related developments that are realistically defined at the time the assessment is
undertaken; and (iv) areas and communities potentially affected by impacts from unplanned but
predictable developments caused by the project that may occur later or at a different location. (para 6,
Appendix 1, SPS,)
IFC Cumulative impacts that result from the incremental impact, on areas or resources used or directly
impacted by the project, from other existing, planned or reasonably defined developments at the time the
risks and impacts identification process is conducted. (para 8, PS1)
Source: Prepared by JICA Study Team based on respective SGPs

3.4.8 Consideration for Protected Area, Biodiversity and Critical Natural Habitats in the ESIA

1
Para 23.4 of WB ESS 1 GN describes “Borrowers are not expected to assess or mitigate induced impacts due to their
unknown, speculative, uncertain, or remote nature” and also “[i]mpacts that are merely possible, or that are considered
“speculative,” are not reasonably foreseeable.”

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under MDBs’ SGP

Impact assessment on the protected area, biodiversity and critical natural habitats in the ESIA under
MDBs’ SGPs was reviewed as a reference for Appendix “Compliance with Laws, Standards, and
Plans” of JICA GL.

Evaluation of Risks and Impacts

Required practices by WB, IFC and ADB are summarized below:

WB: “Where the environmental and social assessment has identified potential risks and impacts on
biodiversity or habitats, the Borrower will manage those risks and impacts in accordance with the
mitigation hierarchy and GIIP. The Borrower will adopt a precautionary approach and apply
adaptive management practices in which the implementation of mitigation and management
measures are responsive to changing conditions and the results of project monitoring.” (para 12,
ESS6)

ADB: “The borrower/client will assess the significance of project impacts and risks on biodiversity
and natural resources as an integral part of the environmental assessment process specified in paras.
4–10. The assessment will focus on the major threats to biodiversity, which include destruction of
habitat and introduction of invasive alien species, and on the use of natural resources in an
unsustainable manner. The borrower/client will need to identify measures to avoid, minimize, or
mitigate potentially adverse impacts and risks and, as a last resort, propose compensatory measures,
such as biodiversity offsets, to achieve no net loss or a net gain of the affected biodiversity.” (para
24, Appendix 1, SPS)

IFC: IFC PS 6 states that “[t]he risks and impacts identification process as set out in PS 1 should
consider direct and indirect project-related impacts on biodiversity and ecosystem services and
identify any significant residual impacts. … As a matter of priority, the client should seek to avoid
impacts on biodiversity and ecosystem services. When avoidance of impacts is not possible,
measures to minimize impacts and restore biodiversity and ecosystem services should be
implemented. …Given the complexity in predicting project impacts on biodiversity and ecosystem
services over the long term, the client should adopt a practice of adaptive management in which the
implementation of mitigation and management measures are responsive to changing conditions and
the results of monitoring throughout the project’s lifecycle.” (para.6-10, PS6).

BMP

Required practices by WB, IFC and ADB are summarized below:

WB: “[w]here significant risks and adverse impacts on biodiversity have been identified, the
Borrower will develop and implement a [BMP]” (para 9, ESS 6). BMP includes the purpose of
biodiversity management, summary of the activities, mitigation measures, implementation schedule,

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institution and responsibility, costs, and others,” (Appendix 1, GN 6).

ADB: There is no description on the BMP or any other relevant action plan.

IFC: “ In such cases where a client is able to meet the requirements defined in paragraph 17, the
project’s mitigation strategy will be described in a Biodiversity Action Plan and will be designed to
achieve net gains of those biodiversity values for which the critical habitat was designated” (para18,
PS6).

Biodiversity Offsets

Required practices by WB, IFC and ADB are summarized below:

WB: “[f]or the protection and conservation of habitats and the biodiversity they support, the
mitigation hierarchy includes biodiversity offsets. Offsets will be considered as a last resort, only if
significant residual adverse impacts remain after all technically and financially feasible avoidance,
minimization, and restoration measures have been considered.”(para15, ESS 6). Additionally, “[a]
biodiversity offset will be designed and implemented to achieve measurable, additional, and long
term conservation outcomes that can reasonably be expected to result in no net loss and preferably
a net gain of biodiversity” (para 16, ESS 6).

ADB: “If some residual impacts are likely to remain significant after mitigation, the EMP will also
include appropriate compensatory measures (offset) that aim to ensure that the project does not
cause significant net degradation to the environment. … Monetary compensation in lieu of
offset is acceptable in exceptional circumstances, provided that the compensation is used to provide
environmental benefits of the same nature and is commensurate with the project’s residual
impact.”(para 13, Appendix 1, SPS). Additionally, “[t]he borrower/client will need to identify
measures to avoid, minimize, or mitigate potentially adverse impacts and risks and, as a last resort,
propose compensatory measures, such as biodiversity offsets, to achieve no net loss or a net gain of
the affected biodiversity” (para 24, Appendix 1, SPS).

IFC: “[f]or the protection and conservation of biodiversity, the mitigation hierarchy includes
biodiversity offsets, which may be considered only after appropriate avoidance, minimization, and
restoration measures have been applied. A biodiversity offset should be designed and implemented
to achieve measurable conservation outcomes that can reasonably be expected to result in no net
loss and preferably a net gain of biodiversity; however, a net gain is required in critical habitats”
(para 10, PS6).

Definition of Habitats

Habitats are defined by WB, ADB and IFC as shown in Table 3-18. The definitions by these 3
organizations are quite similar; however, IFC and ADB have included “areas associated with key
evolutionary processes in the critical habitat. Moreover, ADB has included importance of the

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habitats for local communities in the definition. Lastly, there is no requirement for development in
modified habitats in the SGP of WB, ADB and IFC.

Table 3-18 Definition of Habitats


SGP Definition
WB ESS 6 WB defined the habitats include “a terrestrial, freshwater, or marine geographical unit or airway
that supports assemblages of living organisms and their interactions with the nonliving
environment” and classified into 3 types, namely modified habitat, natural habitat and critical
habitat as shown below.
Modified habitat: Modified habitats are areas that may contain a large proportion of plant
and/or animal species of nonnative origin, and/or where human activity has substantially
modified an area’s primary ecological functions and species composition. Modified habitats may
include, for example, areas managed for agriculture, forest plantations, reclaimed coastal zones,
and reclaimed wetlands. (ESS6 para 19)
Natural habitat: Natural habitats are areas composed of viable assemblages of plant and/or
animal species of largely native origin, and/or where human activity has not essentially modified
an area’s primary ecological functions and species composition. (ESS6 para 21)
Critical habitat: Critical habitat is defined as areas with high biodiversity importance or value,
including:
(a) habitat of significant importance to Critically Endangered or Endangered species, as listed in
the IUCN Red List of threatened species or equivalent national approaches
(b) habitat of significant importance to endemic or restricted-range species
(c) habitat supporting globally or nationally significant concentrations of migratory or
congregatory species
(d) highly threatened or unique ecosystems
(e) ecological functions or characteristics that are needed to maintain the viability of the
biodiversity values described above in (a) to (d).
ADB SPS Modified habitat: In areas of modified habitat, where the natural habitat has apparently been
altered, often through the introduction of alien species of plants and animals, such as in
agricultural areas (para 25)
Natural habitat: Land and water areas where the biological communities are formed largely by
native plant and animal species, and where human activity has not essentially modified the area’s
primary ecological functions. (Glossary)
Critical habitat: A subset of both natural and modified habitat that deserves particular attention.
Critical habitat includes areas with high biodiversity value, including habitat required for the
survival of critically endangered or endangered species; areas having special significance for
endemic or restricted-range species; sites that are critical for the survival of migratory species;
areas supporting globally significant concentrations or numbers of individuals of congregatory
species; areas with unique assemblages of species or that are associated with key evolutionary
processes or provide key ecosystem services; and areas having biodiversity of significant social,
economic, or cultural importance to local communities. (Footnote 5)
IFC PS6 Modified habitat: Modified habitats are areas that may contain a large proportion of plant
and/or animal species of non-native origin, and/or where human activity has substantially
modified an area’s primary ecological functions and species composition. (para 11)
Natural habitat: Natural habitats are areas composed of viable assemblages of plant and/or
animal species of largely native origin, and/or where human activity has not essentially modified
an area’s primary ecological functions and species composition. (para 13)
Critical habitat: Areas with high biodiversity value, including (i) habitat of significant
importance to Critically Endangered and/or Endangered11 species; (ii) habitat of significant
importance to endemic and/or restricted-range species; (iii) habitat supporting globally
significant concentrations of migratory species and/or congregatory species; (iv) highly
threatened and/or unique ecosystems; and/or (v) areas associated with key evolutionary
processes. (para 16)
Source: Prepared by JICA Study Team based on respective SGP

Requirements for the Development Project in the Natural Habitat

Requirements for the development project in the Natural Habitat are summarized in Table 3-19.

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Table 3-19 Requirements for the Development Project in the Natural Habitat
SGP Requirements
WB ESS 6 If natural habitats are identified as part of the assessment, the Borrower will seek to avoid
adverse impacts on them in accordance with the mitigation hierarchy. Where natural habitats
have the potential to be adversely affected by the project, the Borrower will not implement any
project-related activities unless:
(a) There are no technically and financially feasible alternatives.
(b) Appropriate mitigation measures are put in place, in accordance with the mitigation
hierarchy, to achieve no net loss and, where feasible, preferably a net gain of biodiversity over
the long term. When residual impacts remain despite best efforts to avoid, minimize and mitigate
impacts, and where appropriate and supported by relevant stakeholders, mitigation measures may
include biodiversity offsets adhering to the principle of “like-for-like or better.” (para 22)
ADB SPS In areas of natural habitat, the project will not significantly convert or degrade such habitat,
unless the following conditions are met:
(i) No alternatives are available.
(ii) A comprehensive analysis demonstrates that the overall benefits from the project will
substantially outweigh the project costs, including environmental costs.
(iii) Any conversion or degradation is appropriately mitigated.
Mitigation measures will be designed to achieve at least no net loss of biodiversity. They may
include a combination of actions, such as postproject restoration of habitats, offset of losses
through the creation or effective conservation of ecologically comparable areas that are managed
for biodiversity while respecting the ongoing use of such biodiversity by Indigenous Peoples or
traditional communities, and compensation to direct users of biodiversity. (para 26, 27)
IFC PS6 The client will not significantly convert or degrade natural habitats, unless all of the following
are demonstrated:
· No other viable alternatives within the region exist for development of the project on
modified habitat.
· Consultation has established the views of stakeholders, including Affected
Communities, with respect to the extent of conversion and degradation.
· Any conversion or degradation is mitigated according to the mitigation hierarchy.
In areas of natural habitat, mitigation measures will be designed to achieve no net loss of
biodiversity where feasible. Appropriate actions include:
· Avoiding impacts on biodiversity through the identification and protection of set-
asides
· Implementing measures to minimize habitat fragmentation, such as biological
· corridors
· Restoring habitats during operations and/or after operations
· Implementing biodiversity offsets. (para 14, 15)
Source: Prepared by JICA Study Team based on respective SGP

Requirements for the Development Project in the Critical Natural Habitats

Requirements for the development project in the Critical Natural Habitats are summarized in Table
3-20.

Table 3-20 Requirements for the Development Project in the Critical Natural Habitat/Critical
Habitat
SPS Requirements
WB ESS 6 In areas of critical habitat, the Borrower will not implement any project activities that have
potential adverse impacts unless all of the following conditions are met (para 24):
a) No other viable alternatives within the region exist for development of the
project in habitats of lesser biodiversity value.
b) All due process required under international obligations or national law that is a prerequisite
to a country granting approval for project activities in or adjacent to a critical habitat has
been complied with.
c) The potential adverse impacts, or likelihood of such, on the habitat will not lead to
measurable net reduction or negative change in those biodiversity values for which the
critical habitat was designated.

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SPS Requirements
d) The project is not anticipated to lead to a net reduction in the population13 of any Critically
Endangered, Endangered, or restricted-range species, over a reasonable time period.14
e) The project will not involve significant conversion or significant degradation of critical
habitats. In circumstances where the project involves new or renewed forestry or
agricultural plantations, it will not convert or degrade any critical habitat.
f) The project’s mitigation strategy will be designed to achieve net gains of those biodiversity
values for which the critical habitat was designated.
g) A robust and appropriately designed, long-term biodiversity monitoring and evaluation
program aimed at assessing the status of the critical habitat is integrated into the Borrower’s
management program.
ADB SPS No project activity will be implemented in areas of critical habitat unless the following
requirements are met (para 28):
(i) There are no measurable adverse impacts, or likelihood of such, on the critical habitat which
could impair its high biodiversity value or the ability to function.
(ii) The project is not anticipated to lead to a reduction in the population of any recognized
endangered or critically endangered species6 or a loss in area of the habitat concerned such that
the persistence of a viable and representative host ecosystem be compromised.
(iii) Any lesser impacts are mitigated in accordance with para. 27. (para 28)
※para 27. Mitigation measures will be designed to achieve at least no net loss of biodiversity.
They may include a combination of actions, such as postproject restoration of habitats, offset of
losses through the creation or effective conservation of ecologically comparable areas that are
managed for biodiversity while respecting the ongoing use of such biodiversity by Indigenous
Peoples or traditional communities, and compensation to direct users of biodiversity.
IFC PS6 In areas of critical habitat, the client will not implement any project activities unless all of the
following are demonstrated (para 17):
a) No other viable alternatives within the region exist for development of the project on
modified or natural habitats that are not critical.
b) The project does not lead to measurable adverse impacts on those biodiversity values for
which the critical habitat was designated, and on the ecological processes supporting those
biodiversity values.
c) The project does not lead to a net reduction in the global and/or national/regional
population of any Critically Endangered or Endangered species over a reasonable period of
time.
d) A robust, appropriately designed, and long-term biodiversity monitoring and evaluation
program is integrated into the client’s management program.
Source : Prepared by JICA Study Team based on respective SGP

Definition of Protected Areas and Requirements for the Development Project in the Protected
Area under MDBs’ SGP

In addition to the above-mentioned habitats, the definition and requirements for legally protected
areas under MBDs’ SGP are summarized as follows:

WB: ESS6 include “an area that is legally protected, designated for protection, or regionally or
internationally recognized” in protected areas (para 26, ESS 6). The protected areas consist of “[a]
clearly defined geographical space, recognized, dedicated and managed, through legal or other
effective means, to achieve the long-term conservation of nature with associated ecosystem services
and cultural values” (footnote 15, ESS 6).

As for Internationally recognized areas of high biodiversity value, “World Heritage Natural Sites,
Biosphere Reserves, Ramsar Wetlands of International Importance, [KBA], [IBA], and Alliance for
Zero Extinction Sites, among others” are included (footnote 16, ESS 6).

ADB: ADB SPS also describes requirements for legally protected areas; however, the definition and
examples are not available in the SPS (para 30, Appendix 1, SPS).

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IFC: PS6 recognizes “legally protected areas that meet the IUCN definition: “A clearly defined
geographical space, recognized, dedicated and managed, through legal or other effective means, to
achieve the long-term conservation of nature with associated ecosystem services and cultural values.”
For the purposes of this Performance Standard, this includes areas proposed by governments for
such designation” (footnote 16, PS 6).

Internationally recognized areas include UNESCO Natural World Heritage Sites, UNESCO Man
and the Biosphere Reserves, KBA, and wetlands designated under the Convention on Wetlands of
International Importance (the Ramsar Convention) and others” (footnote 17, PS 6).

Table 3-21 Requirements for the Protected Areas


SGP Requirements
WB ESS 6 The Borrower will meet the requirements of paragraphs 13 through 25 of this ESS, as applicable.
In addition, the Borrower will:
a) Demonstrate that the proposed development in such areas is legally permitted.
b) Act in a manner consistent with any government recognized management plans for such
areas.
c) Consult and involve protected area sponsors and managers, project-affected parties
including Indigenous Peoples, and other interested parties on planning, designing,
implementing, monitoring, and evaluating the proposed project, as appropriate.
d) Implement additional programs, as appropriate, to promote and enhance the conservation
aims and effective management of the area. (para27)
ADB SPS In circumstances where some project activities are located within a legally protected area, in
addition to the requirement specified in para. 28, the borrower/client will meet the following
requirements:
(i) Act in a manner consistent with defined protected area management plans.
(ii) Consult protected area sponsors and managers, local communities, and other key
stakeholders on the proposed project.
(iii) Implement additional programs, as appropriate, to promote and enhance the conservation
aims of the protected area. (para30)
IFC PS6 In circumstances where a proposed project is located within a legally protected area or an
internationally recognized area, the client will meet the requirements of paragraphs 13 through
19 of this Performance Standard, as applicable. In addition, the client will:
a) Demonstrate that the proposed development in such areas is legally permitted.
b) Act in a manner consistent with any government recognized management plans for such
areas.
c) Consult protected area sponsors and managers, Affected Communities, Indigenous Peoples
and other stakeholders on the proposed project, as appropriate.
a) Implement additional programs, as appropriate, to promote and enhance the conservation
aims and effective management of the area.(PS 6, para 20)
Implementing additional programs may not be necessary for projects that do not create a new
footprint.(Footnote 18)
Source: Prepared by JICA Study Team based on respective SGP

Applicability of the SGP to Supply Chain

Applicability of the SGPs of the MDBs to supply chain is summarized as below:

 WB: ESS6 states “[w]here a Borrower is purchasing natural resource commodities, including
food, timber and fiber, that are known to originate from areas where there is a risk of significant
conversion or significant degradation of natural or critical habitats, the Borrower’s
environmental and social assessment will include an evaluation of the systems and verification
practices used by the primary suppliers. The Borrower will establish systems and verification
practices which will: (a) identify where the supply is coming from and the habitat type of the

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source area; (b) where possible, limit procurement to those suppliers that can demonstrate that
they are not contributing to significant conversion or degradation of natural or critical habitats;
and (c) where possible and within a reasonable period, shift the Borrower’s primary suppliers
to suppliers that can demonstrate that they are not significantly adversely impacting these areas.
(para38, 39, ESS6) Additionally, it states “[t]he ability of the Borrower to fully address these
risks will depend upon the Borrower’s level of control or influence over its primary suppliers.”
(para 40, ESS6).

 ADB: SPS does not specify the applicability clearly.


 IFC: the client is required to confirm the primary supplier’s evaluation in terms of environment
and social aspects and its verification, more specifically “The systems and verification
practices will (i) identify where the supply is coming from and the habitat type of this area; (ii)
provide for an ongoing review of the client’s primary supply chains; (iii) limit procurement to
those suppliers that can demonstrate that they are not contributing to significant conversion of
natural and/or critical habitats (this may be demonstrated by delivery of certified product, or
progress towards verification or certification under a credible scheme in certain commodities
and/or locations); and (iv) where possible, require actions to shift the client’s primary supply
chain over time to suppliers that can demonstrate that they are not significantly adversely
impacting these areas. The ability of the client to fully address these risks will depend upon the
client’s level of management control or influence over its primary suppliers.” (para 30, IFC
PS6)

Illegal Activities on Ecosystem and Biodiversity

Current JICA GL state that illegal logging is one of the illegal activities which should be avoided.
MDBs’ SGPs regarding such illegal activities on ecosystem and biodiversity, including illegal
logging, are reviewed. Based on the premise of that a project complies the national legislations of
the borrower’s country, stipulations in the MDBs’ SGPs about such illegal activities which should
be avoided by the project are summarized below.

 WB ESS6 does not describe any other illegal activities on Ecosystem and Biodiversity which
should be avoided by the borrower.
 ADB SPS prohibits “production of or trade in any product or activity deemed illegal under host
country laws or regulations or international conventions and agreements or subject to
international phaseouts or bans, such as …. (d) wildlife or wildlife products regulated under
the Convention on International Trade in Endangered Species of Wild Fauna and Flora” in
Appendix 5 ADB Prohibited Investment Activities List of SPS.
 IFC PS6 does not specify any other illegal activities on Ecosystem and Biodiversity which
should be avoided by the client.

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3.5 Comparison among Bilateral Donors’ SGPs

The SGPs of major bilateral funding agencies both in developed countries and emerging countries
are studied based on the public information disclosed on their websites. The target agencies which
provide various assistance, such as providing funding and technical assistance as JICA does were
selected and include AFD, Kreditanstalt fur Wiederaufbau, Germany (KFW), Department for
International Development, UK (DFID), Commonwealth Development Corporation, UK (CDC),
Millennium Challenge Corporation, USA (MCC), Overseas Private Investment Corporation, USA
(OPIC), United States Agency for International Development (USAID), Economic Development
Cooperation Fund/Export-Import Bank of Korea (EDCF/KEXIM), Export-Import Bank of China
(CEXIM), and Neighbouring Countries Economic Development Cooperation Agency, Thailand
(NEDA).

However, information of the SGPs of DFID and CEXIM are included in Table 3-22 (1) and (2) as a
reference since these SGPs are not fully or partially available on their website and not fully
confirmed.

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Table 3-22 (1) Survey on Bilateral Donor Agencies' SGPs (France, Germany, UK)

No. Items AFD (France) KfW( Development Bank)(Germany) DFID (United Kingdom) CDC (United Kingdom)
General Outline
1 Outline of the ・There is no policy paper which is equivalent to the ・According to the German Federal Ministry for Economic ・In 2015 "UK Aid: Tackling global challenges in the national interest"6 was published, and it declares the followings:
government policy on Development Cooperation Charter; however, according to Cooperation and Development (BMZ) website 4, the target ・It is targeted to spending 0.7% of Gross National Income (GNI) on international development. (Para 2, Foreword, "UK
bilateral assistance the public information on the French Foreign Ministry of BMZ’s development policy is freedom and security for Aid: Tackling global challenges in the national interest")
(which is equivalent website, the summary of its policy is as follows: all; a life without poverty, fear and environmental ・British interests are tackling to the threat of terrorism and global climate change, not the causes of mass migration and
to the Development ・Provide assistance through loans, grants and technical destruction. German bilateral official development disease, and the strategic areas to be supported by UK are “strengthening global peace, security and governance”,
Cooperation Charter cooperation in line with the needs of the recipient country. cooperation consists of the economic cooperation and the “strengthening resilience and response to crises”, “promoting global prosperity”, and “tackling extreme poverty and helping
of the Japanese The emphasis is on Africa, conflict affected countries, technical cooperation. (“International Cooperation”, “The the world’s most vulnerable.” (Para 8, Foreword, "UK Aid: Tackling global challenges in the national interest")
Government) etc.(“French official development assistance; priorities, direct approach to the partner”, “Working approach”, ・As a result of a new approach, British Government will allocate 50% of all DFID’s spending to fragile states and regions,
principles & key figures”, “Development Assistance”, “Aims”, “Ministry” on BMZ website) increase aid spending for the Syrian crisis and the related region, fund to global public health, and shift from “general budget
French Foreign Ministry website1) ・According to the BMZ issued Guidelines for Bilateral support” to “target spending” (Para 13, Foreword, "UK Aid: Tackling global challenges in the national interest")
France declares four prioritized areas as follows: Financial and Technical Cooperation (February 2019) 5, the ・Assistance in climate change program “will be delivered through a cross-government effort, including crisis response such
 The fight against climate change and environmental priority areas of German development cooperation include as disaster prevention and the additional investment in clean energy innovation”. (Climate Change Box 3.D, "UK Aid:
conservation realizing democracy, civil society, development of peace, Tackling global challenges in the national interest")
 Human development and gender equality education, health, environmental policy, sustainable ・The government strive to end sexual violence, Female Genital Mutilation (FGM) and child, early and forced marriage, in
 Economic development for social progress economic development, energy, etc. 5 (2 Priority areas, conflict as social considerations for the vulnerable groups. (3.17, "UK Aid: Tackling global challenges in the national
 Strengthening human rights, stability and peace. BMZ Guidelines for Bilateral Financial and Technical interest")
(Same as above) Cooperation) ・The government will aim for all UK government departments to be ranked as ‘Good’ or ‘Very Good’ in the international
・France has formulated separate policies on sustainable Aid Transparency Index. (4.11, "UK Aid: Tackling global challenges in the national interest")
development, human rights, gender, etc. in addition to the As for the institutional arrangement, under BMZ, the ・ There is no specific description on environmental and social considerations and SGPs.
development assistance policy. (Listed at the bottom of Kreditanstalt für Wiederaufbau (KfW) is in charge of
above-mentioned “French Foreign Policy”) financial cooperation (FC) and the Deutsche Gesellschaft
-While emphasizing considerations to Effectiveness, für Technische Zusammenarbeit (GTZ) is in charge of
Transparency & Accountability, there is no description on technical cooperation (TC). (16, BMZ Guidelines for
environmental and social considerations and SGPs. bilateral Financial and Technical Cooperation)
(“Principles of French official development assistance”
from the above-mentioned Ministry of Foreign Affairs
site. 2)
・France is the second-largest contributor to the European
Development Fund (EDF) and through its contribution,
helps countries and sectors which France can provide
assistance and aims at realizing the diplomatic policy of
France or EU (“France and EU Development Policy” from
the above-mentioned Ministry of Foreign Affairs site. 3)
SGPs
SGP name Environmental and Social Risk Management Policy for KfW Development Bank Sustainability Guideline; ・ SMART Rules : Better Programme Delivery (April ・CDC’s Code of Responsible Investing (March 2017)
(Note: For each SGP website, AFD-funded Operations Assessment of Environmental, Social, and Climate 2019) 7 ・Climate Change Policy8
see the list below) Performance: Principles and Process (April 2016) ・Technical Guidance (environmental impact assessments, ・Gender Equality Position Statement 9
social impact applications, conflict analysis, assessment ・ Commitments to strength safeguards measures against
evidence, and benefit feedback) has not been disclosed on sexual exploration, abuse and sexual harassment in the
the website. The following explanations refer to the above development finance sector (SEA policy paper)
SMART Rules. ・Environmental, Social, Governance (ESG) Toolkit (website)

1
French Ministry for Europe and Foreign Affairs, French official development assistance; priorities, principles & key figures: https://www.diplomatie.gouv.fr/en/french-foreign-policy/development-assistance/french-official-development/
2
French Ministry for Europe and Foreign Affairs, Principles of French official development assistance: https://www.diplomatie.gouv.fr/en/french-foreign-policy/development-assistance/french-official-development/principles-of-french-development/
3
French Ministry for Europe and Foreign Affairs, France and EU Development Policy: https://www.diplomatie.gouv.fr/en/french-foreign-policy/development-assistance/france-and-eu-development-policy/
4
The Federal Ministry for Economic Cooperation and Development (BMZ): http://www.bmz.de/en/ministry/index.html, http://www.bmz.de/en/ministry/approaches/bilateral_development_cooperation/index.html
5
Federal Ministry of Economic Cooperation and Development, Guidelines for bilateral Financial and Technical Cooperation with cooperation partners of German development cooperation (February 2019):
https://www.bmz.de/en/zentrales_downloadarchiv/wege_und_akteure/190221_Guidelines_Financial_and_Technical_Cooperation.pdf
6
DFID, UK aid tackling global challenges in the national interest: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/478834/ODA_strategy_final_web_0905.pdf
7
Version XI: effective 1st April 2019 until 1st October 2019. Smart Rules is DFID's operating framework, and shows the due diligence implementation policy etc. throughout the program cycle. (Smart Rules, Executive Summary) Technical Guidance is introduced in Smart Rules as
business reference materials and guidance covering a wide range of fields such as environmental and social impact assessment. (1.3 Discretionary resources and guidance, Smart Rules)
8
Climate Change Policy: https://assets.cdcgroup.com/wp-content/uploads/2018/06/25150830/Climate-Change-Policy.pdf
9
Gender Equality Position Statement: https://assets.cdcgroup.com/wp-content/uploads/2018/07/11143751/Gender-Position-Statement.pdf

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No. Items AFD (France) KfW( Development Bank)(Germany) DFID (United Kingdom) CDC (United Kingdom)
1

(Refer to the underlined code unless otherwise stated below)


2 Documents to be ・There is no description on information disclosure by ・There is no specific description. • According to SMART Rules, it is supposed to refer to the ・There is no description on the documents to be disclosed,
disclosed, disclosure AFD. Technical Guidance for specific measures (1.3 disclosed period and method in the Code.
period, and method ・AFD supports disclosure by clients, but disclosure by Discretionary resources and guidance in Part 1); however, ・ The Code reflects international standards and practices
for environmental clients is not mandatory.(”the client will be encouraged it is not possible to confirm it because the Technical including IFC Performance Standards and it is considered to
and social to make these documents available to the public.”) Guidance is not disclosed on the website. be dealt with along the IFC requirements. (para 2, Text 1.1)
considerations ・Documents subject to information disclosure
documents (recommended): EIA/ESIA, ESMP, RAP, etc. (For
projects of High, Substantial, Moderate risk category)
•Once the environmental and social documents have been
reviewed by AFD, AFD requests the executing agency
disclose the ESIA, ESMP and/or RAP in the borrower’s
country so that major stakeholders can access them, and to
ensure the timeline for stakeholder meetings in which
comments are incorporated. The client will also be
encouraged to disclose updated ESIA, ESMP or RAP in
the accessible place such as their offices or via the
Internet. (Disclosure of information: Analysis of the
documentation in 3. Principles)
3 Categorization  Categorization of the environmental and social risk: ・All FC measures will be classified into one of the ・ There is no specific description in SMART Rules. ・The Code does not specify the method of categorization,
Method AFD analyzes and classifies all potential projects into following three categories “A”, “B” or “C” 2, according to According to SMART Rules, it is supposed to refer to the however, the Code is based on international standards
High – Substantial – Moderate – Low environmental the relevance of their potentially adverse environmental and Technical Guidance for specific measures (1.3 including IFC PSs. (para 2, Text 1.1)
and social risks, depending on the extent of the social impacts and risks. Additionally, screening will be Discretionary resources and guidance in Part 1), but it is not • According to CDC's ESG Toolkit 3 , uniform rules for
potential risks borne by the project. conducted for a possibility to reduce GHG emission and a possible to confirm it because the Technical Guidance is categorization are not defined; however, it is recommended to
 The classification takes into account the nature and necessity of mitigation measures for climate change. not disclosed on the website. categorize into High, Medium (Medium-High, Medium-Low)
scale of the project, the location and sensitivity of the (4.3.2.1) and Low according to IFC PSs etc. Along these categories, the
affected area, the severity of the potential ・10.1 Annex 1 illustrates the list of FC measures and scope and level of E & S Due Diligence will be determined.
environmental and social risks and impacts, as well sector examples which may have potential significant (ESG Toolkit, “Proposed E&S Inherent risks/impacts
as the client’s capacity to manage them. adverse environmental and social impacts (assigned to Categorisation”)
 By category, the scope of the environmental and category A or B). ・According to CDC's ESG Toolkit, categorization takes into
social assessment, the level of environmental account the project mitigation measures in addition to project
standards, the scope of stakeholders engagement risks / impacts. However, the borrower’s management and
and the level of information required are decided for response capability of E&S risks / impacts is not considered in
projects. the categorization (assessing the management ability of the
(Categorization of the environmental and social risk borrower etc. according to the category.) (ESG Toolkit
in 3. Principles) website)
4 Referred ・AFD has adopted the WB’s prevailing environmental  Compulsory for the ESDD of a FC measures are the There is no specific description in SMART Rules. ・The requirements of IFC PSs and WBG EHS Guidelines are
International standard and social operational standards to projects with standards of the WB Group (i.e. for public agencies the According to SMART Rules, it is supposed to refer to the applied. 8 9 (para 2 of Section 1.1, and the second half of
(. Whether it refers to environmental and social risks categorized as High or Environmental and Social Safeguards of the WB and Technical Guidance for specific measures (1.3 Schedule 4 “Additional E&S Requirements for Specific
an international Substantial. For other operations, the projects must be the IFC Performance Standards for cooperation with Discretionary resources and guidance in Part 1), but it is not Circumstances”)
organization or some appraised and implemented in compliance with the the private sector) and their General and sector-specific possible to confirm it because the Technical Guidance is ・ The Code says it reflects international standards and
international standard prevailing national environmental and social regulations in EHSG as well as the Core Labour Standards of the practices including UN Guiding Principles on Business and
as JICA GL do). Human Rights. Thus, the principles are considered to refer to
as appropriate. (Text 1.1 paragraph 2)
・Low categorized projects are also subject to basic E&S due

1
CDC ESG Toolkit:https://toolkit.cdcgroup.com/
2
Category A: If they may have diverse significant adverse impacts and risks on the environment and the social conditions of the affected population. Impacts and risks may potentially be significantly adverse because the complex nature of the FC measure, the scale (large to very large),
the sensitivity of the location(s) of the FC measure or the impacts and risks are irreversible or unprecedented. Such impacts and risks may affect a larger area that is beyond the site of the facility under construction, the facility itself as well as any associated facilities or the FC measure
area in a narrower sense. (4.3.2.2)
Category B: If they may have potentially adverse risks and impacts upon the environment and on the social conditions of those concerned. However, the impacts and risks may have a lesser extent than these of category A FC measures and can usually be mitigated through state-of-the-art
mitigation measures or standard solutions. Typically, the potential impacts and risks of category B FC measures are limited to a local area, are in most cases reversible and are easier to mitigate through appropriate measures. (4.3.2.4)
Category C: If they are expected to have no or only minor adverse environmental and social impacts or risks and if the implementation and operation of the FC measure does not require any particular protection, compensation or monitoring measures. (4.3.2.5)
3
CDC ESG Toolkit website、Screening and Categorization: https://toolkit.cdcgroup.com/investment-cycle/screening-and-categorisation/
8
The second paragraphs in CDC 1.1. "Code of Responsible Investing" have the following description. ”It [the Code] reflects international standards and practices including the International Finance Corporation’s Performance Standards, and the UN
Guiding Principles on Business and Human Rights. It also reflects CDC’s requirements in relation to climate change.
9
CDC "Code of Responsible Investing", Schedule 4 "Additional E & S Requirements for Specific Circumstances" in the second half (2 paragraphs from the bottom of page 8) has the following description. ” the requirements of relevant IFC PSs and EHS Guidelines should be met.”

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No. Items AFD (France) KfW( Development Bank)(Germany) DFID (United Kingdom) CDC (United Kingdom)
the country where the project takes place. 1 ILO.(4.2.2. 2) not released on the web4. diligence process, and the project will be reviewed for
( Environmental and social reference standards in 3.  If the FC measure involves funds related to the occupational health and safety, labour standards and, in some
Principles) European Union (EU) or is financed in countries with cases, energy efficiency. (ESG Toolkit, “Proposed E&S
・AFD may apply cofinancer’s SGP when cofinance EU membership prospects, the environmental and Inherent risks/impacts Categorisation”)
project. If AFD is not the coordinator of the financing, social standards of the EU also apply. (4.2.2. 3)
AFD assesses the environmental and social documents
produced under the responsibility of the client and/or lead
funder. AFD may request additional information and/or
implement complementary due diligence. When AFD is
the lead or coordinator of the financing, AFD requires the
cofinancers and the borrowers to use the AFD procedures
for the due diligence.
(3. Principles' Cofinancing Operations)
5 Socially vulnerable • There is no provision for the definition of socially ・There is no special description concerning the definition There is no specific description in SMART Rules. ・There is no provision of the definition of socially vulnerable
groups, or special vulnerable groups, other than seeking the participation of of and considerations for the socially vulnerable groups. According to SMART Rules, it is supposed to refer to the groups in the Code.
considerations vulnerable groups in stakeholder consultations. (3. Technical Guidance for specific measures (1.3 ・In the Code, it includes banning of forced labour; banning
Principles Stakeholder participation-consultation) Discretionary resources and guidance in Part 1), however, of child labour; pay wages which meet or exceed industry or
it is not possible to confirm it because the Technical legal national minima; no discrimination in terms of
Guidance is not available on the website. recruitment and progression (on the basis of gender, race, and
any other social backgrounds, etc.); and respect for the right of
all workers. (Middle lines of “General Requirements” in
Schedule 3.)
6 Response to climate ・ There is no special provision. ・A Climate Assessment is conducted to identify and There is no specific description in SMART Rules. •If GHG emissions are expected and the requirements of the
change (Estimates of ・ It is assumed that measures will be required in line prevent any adverse impacts and risks, or minimize them to According to SMART Rules, it is supposed to refer to the IFC PS and EHS guidelines are applicable, appropriate impact
GHG emissions, with the WB ESS, etc., since AFD has adopted the WB’s an acceptable level in addition to ESDD. (4.1.1. ) Technical Guidance for specific measures (1.3 assessment needs to be conducted, and mitigation measures as
emissions thresholds prevailing environmental and social operational standards. ・When screening or assessing impacts, the possibility of Discretionary resources and guidance in Part 1), however, per the Climate Change Policy of the CDC will be sought.
for which estimates GHG emission reductions and the need for adaptation it is not possible to confirm it because the Technical (Latter half of Schedule 4 “Additional E & S Requirements for
are required, measures against climate change need to be considered. Guidance is not disclosed on the website. Specific Circumstances”)
consideration of (4.3.1 , 4.3.3.1) ・Climate Change Policy (September 2014) was formulated
alternatives with ・When carrying out the in-depth climate assessment, it separately, and it is mentioned that the policy aims to evaluate
lower GHG must be confirmed whether it is a compatible with the risk / impact on climate change, support transition to lower
emissions, and National Adaptation Plan (NAP). Also when carrying out carbon society, and support introducing renewable energy.
confirmation of the in-depth climate assessment, it needs to be confirmed The policy on coal-fired power generation was formulated
consistency with the whether it is compatible with the NDC. (4.4.5) separately. (1.1 and 1.2, Climate Change Policy)
counterpart country's ・There is no description on the concept of GHG emissions ・The CDC actively assesses climate change risks, and in its
Nationally for which estimation is required and the environmental review, energy use efficiency, water use
Determined definition/interpretation of the GHG amount in alternatives. efficiency, climate change adaptation and disaster response
Contributions: NDC) (for large-scale projects susceptible to climate change risk
only) will be assessed from the view point of climate change.
The CDC will also consider providing loans for those
measures as necessary. (Chapter 2, Climate Change Policy
7 Rules on Meaningful • For High and Substantial risk projects, a free, prior ・It is mentioned that information needs to be provided in a There is no specific description in SMART Rules. ・When the negative impact on the environmental society is
Participation of and informed consultation needs to be conducted with timely and culturally appropriate manner (4.6.1).However, According to SMART Rules, it is supposed to refer to the expected in the activities of the company receiving support
Stakeholders affected residents, communities and relevant Civil there is no specific description about “meaningful Technical Guidance for specific measures (1.3 from CDC, an appropriate stakeholder engagement plan
Society Organizations (CSOs). participation”. Discretionary resources and guidance in Part 1); however, should be developed.(Schedule 4 “Additional E&S
• There is no specification of the timing of it is not possible to confirm it because the Technical Requirements for Specific Circumstances”)

1
In 3. Principles of AFD "Environmental and Social Risk Management Policy for AFD-funded Operations" has the following description in "Environmental and social reference standards". “Pursuant to the Paris Declaration on Aid Effectiveness promoting Donor alignment and
coordination, AFD has adopted the WB’s prevailing environmental and social operational standards. These standards apply to projects with environmental and social risks categorized as High or Substantial. For other operations, the projects must be appraised and implemented in
compliance with the prevailing national environmental and social regulations in the country where the operation takes place.”
2
“Compulsory for the ESDD of a FC measures are the standards of the World Bank Group (i.e. for public agencies the Environmental and Social Safeguards of the World Bank and the IFC Performance Standards for cooperation with the private sector) and their General and sector-
specific EHSG as well as the Core Labour Standards of the ILO.”
3
“If the FC measure involves funds related to the EU or is financed in countries with EU membership prospects, the environmental and social standards of the EU also apply.”
4
The following description is given in Part 1, 1.3 Discretionary resources and guidance of DFID "SMART Rules". ”These [a wide range of operational guidance materials] are designed to share learning and improve the way we design, deliver, monitor, evaluate and learn from Business
Plans and programmes. These guides do not contain additional mandatory rules (these are covered within the Smart Rules) but do represent professional good practice. Staff and managers can use their judgement in applying them.
Technical guidance – covering cross-cutting areas such as environmental impact assessments, social impact appraisal, conflict analysis, assessing evidence, and beneficiary feedback – is available on the Evidence and Programme Exchange.
Operational guidance on programme management and delivery is available on the Smart Rules homepage. These are listed as ‘Smart Guides’ and are aligned with the principles and approach of the Smart Rules.”
However, the Guidance has not been obtained.

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No. Items AFD (France) KfW( Development Bank)(Germany) DFID (United Kingdom) CDC (United Kingdom)
consultations, and consultation needs to be conducted Guidance is not available on the website. ・It mentions the need for stakeholder participation in E&S
more than one time in the impact assessment process Due Diligence.
as per the national law.
• The initial consultation must be conducted in a
transparent manner and must be accessible to all
persons potentially affected by the project.
• Local residents need be consulted in a culturally
appropriate manner and a language they can
understand, and measures enable local residents to
understand need to be provided based on their cultural
and educational standards.
• For the high risk projects, or the project has a
significant change during the project implementation
stage, consultation needs to be conducted during the
implementation phase as necessary.
• The results of the consultation will be reflected in the
final draft EIA, etc. and the AFD will review the draft
final EIA. (Stakeholder participation-consultation in
3. Principles)

Source: Respective SGPs as shown below and the footnote

List of Website Links for Reviewed SGPs


 AFD(France):Environmental and Social Risk Management Policy for AFD-funded Operations
https://www.afd.fr/sites/afd/files/2017-10/Environmental-social-risk-management-policy-afd_0.pdf
 AFD GCF(France):Transforming Financial Systems for Climate, Environmental and Social Framework (February 2018)
https://www.afd.fr/sites/afd/files/2018-09-02-18-12/environmental-social-framework-climate.pdf
 KfW(Germany)(KfW Development Bank):KfW Development Bank Sustainability Guideline, Assessment of Environmental, Social, and Climate Performance: Principles and Process (April 2016)
https://www.kfw.de/PDF/Download-Center/Konzernthemen/Nachhaltigkeit/FZ-Nachhaltigkeitsrichtlinie-2014_E.pdf
 DFID(United Kingdom):SMART Rules : Better Programme Delivery
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/791174/Smart-Rules-External-Apr19.pdf
 CDC(United Kingdom):CDC’s Code of Responsible Investing
https://assets.cdcgroup.com/wp-content/uploads/2018/10/29104330/Code_of_Responsible_Investing_March_2017_UPDATE31.pdf

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Table 3-22 (2) Survey on Bilateral Donor Agencies’ SGP (US, Korea, China, Thailand)

No. Items MCC (USA) OPIC (USA) USAID (USA) EDCF / KEXIM (Korea) CEXIM (China) NEDA (Thailand)

General Outline
1 Outline of the ・The Trump administration, which was ordained in January 2017, has not clearly announced the strategy on foreign aid ・ Framework Act on International ・According to the 13th Five-Year Plan ・ There is no policy paper that is
government policy (as of July 2017). However, through the process of budgeting, under the President's "US First" policy, it is Development Cooperation (The for Economic and Social Development equivalent to the Development
policy on revealed that the main mission of the State Department, including the USAID, is promotion of US national security and Framework Act) was formulated, and of the People’s Republic of China Cooperation Charter of Japan.
bilateral economic interests and value, and that international cooperation from the United States needs to be more efficient and in its Article 3, it identifies following 2016-2020 6 , it aims to increase However, according to the public
assistance (which effective 1. five basic principles of the Korea’s overseas aid amount and to improve information on the NEDA website 7 ,
is equivalent to ・Although it is not a policy equivalent to the Development Cooperation Charter of Japan, according to the Joint international development cooperation: methodology, especially focusing on the summary is as follows:
the Development Strategic Plan (JSP) 2 of the United States Department of State and the USAID for FY2018-2022 (February 2018)2, the (i) reduce poverty; (ii) improve the (i) human resources, development ・NEDA is a leading organization that
Cooperation strategic goals of US foreign policy and development assistance (Goals) are set as follows: human rights of women, children and planning, and economic policy; (ii) cooperates with the neighbouring
Charter of the Goal 1: Protect America’s Security at Home and Abroad the disabled, and achieve gender expand foreign cooperation and aid in countries in economic and social
Japanese Goal 2: Renew America’s Competitive Advantage for Sustained Economic Growth and Job Creation equality; (iii) realize sustainable the areas of science, technology, development to expand trade and
Government) Goal 3: Promote American Leadership through Balanced Engagement development and humanitarianism; (iv) education, medical care, disaster investment opportunities among
Goal 4: Ensure Effectiveness and Accountability to the American Taxpayer promote cooperative economic prevention and mitigation, Thailand and its neighbouring
・Strategic Objectives are set under each Goal. For bilateral cooperation, for example, the following Strategic partnership; and (v) pursue peace and environmental governance, the countries. NEDA’s mission is to
Objectives are mentioned under "Goal 2: Renew America's Competitive Advantage for Sustained Economic Growth and prosperity in the international protection of wild fauna and flora, and conduct financial and technical
Job Creation": community. poverty alleviation; and (iii) step up the assistance, integrate with government
Strategic Objective 2.1: Promote American prosperity by advancing bilateral relationships and leveraging international ・The Strategic Plan for International provision of humanitarian aid. and private agencies, plan and
institutions and agreements to open markets, secure commercial opportunities, and foster investment and innovation to Development Cooperation (The (Chapter 53) implement joint projects of related
contribute to U.S. job creation Strategic Plan) was formulated, and its ・China will also actively implement countries, promote private sector
Strategic Objective 2.2: Promote healthy, educated and productive populations in partner countries to drive inclusive and policy includes (i) fulfillment of the 2030 Agenda for SDGs and help participation, and promote capacity
sustainable development, open new markets and support U.S. prosperity and security objectives responsibility as a DAC member, and establish diversified systems for development and organizational
Strategic Objective 2.3: Advance U.S. economic security by ensuring energy security, combating corruption, and (ii) the scale-up of the amount of ODA development financing, help safeguard development so that projects comply
promoting market-oriented economic and governance reforms provided, and the strengthening of the international public security, combat with international standards.
-OPIC and MCC are also included as agencies of Cross Agency Collaboration to realize the above goals. ODA implementation system. It also terrorism, and actively support and ・As the Corporate Value, four items
(Above-mentioned descriptions except 1st item is excerpted from p.35-38, JSP) adopted three core strategies, namely participate in the peacekeeping are listed: Networking, Energy,
(i) sharing Korea’s development operations of the United Nations. Driving Forward, and Accountability.
experiences; (ii) enhancing the ODA (Chapter 53) Accountability includes consideration
system; and (iii) strengthening ・ Capacity building in agricultural for Governance.
inclusive partnership for development. sector (Chapter 18) ・ No description related to
・ The Mid-term Strategy for ・Climate change measures (Chapter environmental and social
Development Cooperation (2016-2020) 46) considerations and SGPs is found.
adopts comprehensive approach and ・China will Promote strengthening of
implements plans such as the bilateral cooperation in the Belt and
Humanitarian Assistance Strategy and Road Initiative(Chapter 51).
the Multilateral Aid Strategy to
contribute to SDGs achievement.
・ No description related to
environmental and social
considerations and safeguard policies is
found in its policy.
(Excerpt from Legal Framework 3 ),
Strategic Plan4, Mid-term Strategy5)
SGPs

1
Ministry of Foreign Affairs Official Development Assistance (ODA) Development Cooperation Reference Material (2017 version) Chapter 3 Economic Cooperation of Other Countries Section 2 Outline of Economic Cooperation of Major Donors and Regional Organizations
(https://www.mofa.go.jp/mofaj/gaiko/oda/files /000409546.pdf) p.246-
2
JSP FY2018-2022 (February 2018) (https://www.state.gov/documents/organization/277156.pdf) JSP is the document in which the United States Department of State and USAID suggest on how to implement US foreign policy and development assistance based on the National Security
Strategy by President Trump. (JSP Overview, p16)
3
Korea ODA Website, Legal Framework: http://www.odakorea.go.kr/eng.policy.StrategicPlan.do
4
Korea ODA Website, Strategic Plan: http://www.odakorea.go.kr/eng.policy.StrategicPlan.do
5
Korea ODA Website, Mid-term Strategy: http://www.odakorea.go.kr/eng.policy.Mid-termODAPolicy.do
6
The 13th Five-Year Plan for Economic and Social Development of the People’s Republic of China 2016-2020 (Translated by Compilation and Translation Bureau, Central Committee of the Communist Party of China)
(http://en.ndrc.gov.cn/newsrelease/201612/P020161207645765233498.pdf)
7
NEDA, Vision and Mission website: https://www.neda.or.th/2018/en/about?n=nGO4ZDWewEb3QWewEb3Q

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No. Items MCC (USA) OPIC (USA) USAID (USA) EDCF / KEXIM (Korea) CEXIM (China) NEDA (Thailand)

SGP name MCC Environmental Guidelines Environmental and Social Policy ・Automated Directives System EDCF Safeguard Policy (2016) Information about CEXIM's SGP has Environmental and Social Safeguards
(* For each SGP website, see the (August 2010) Statement (January 2017) (ADS) Chapter 204 Environmental not been disclosed. Guidelines (January 2019)
list below.) Procedures (February 2013) 1 <Reference Material>
・ China Banking Regulatory
Title 22, Code of Federal Commission (CBRC) ‘Green Credit
Regulations, Part 216 (22 CFR 216) Guidelines (GCG)’(2012)2(GCG)
・The Export-Import Bank of China
‘White Paper on Green Finance’
(2016) 3(White Paper)
2 Documents to be • Implementing entities will be Information Disclosure by OPIC 4 • Scoping statements are circulated ・ It has a section for information ・It was impossible to confirm • It has a section on information
expected to make documents Although disclosure of project-related to the relevant federal agencies if disclosure and clarify the roles and ・According to the Article 24 of GCG, disclosure, and clearly specify the
disclosed, such as ESIA and information is primarily the deemed necessary. Comments are responsibilities of the borrower and “Banking institutions shall make roles and responsibilities of the
disclosure period, environmental management responsibility of Applicants, OPIC is received for 30 days.(216.3(a)(4) Korea Eximbank. public their green credit strategies and borrower and NEDA.
plan publicly available and committed to making non-confidential (iii) , 22 CFR 216) ・ Korea Eximbank shall post the policies, and fully disclose • It requests that information be
and method for
easily accessible. (5. Public project-specific information available. ・ Information disclosure is environmental and social documents developments of their green credit disclosed to a wide range of
information Consultation and Disclosure) Project-related information that is conducted based on the Freedom of (Draft or final non-technical summary business. As for credit involving major stakeholders on the website from
• There is no detailed provision posted on the OPIC website includes Information Act. Interested persons of ESIA/IEE report, draft or final environmental and social risks, the the early stage of project
disclosure
on the document subject to project summaries, summaries of OPIC can obtain information and reports summary of RAP / IPP) on its website banking institutions shall disclose formation so that comments can
regarding information disclosure, the environmental and social monitoring on EA and EIS. (216.10, 22 CFR for Category A and Category B relevant information according to laws be fed back to project formation.
environmental disclosure period and method. reports, and OPIC’s active portfolio list. 216) projects. (41.) 6 and regulations.” • NEDA discloses information on
OPIC may withhold records or portions The draft Environmental Impact • Korea Eximbank requires the ・ There is no specific description in environmental and social
and social of records that are exempted from Statement will be notified and borrower to ensure that relevant White Paper. considerations, in order to ensure
considerations public disclosure under the Freedom of posted in the Federal Register and environmental and social accountability and to promote the
Information Act (FOIA). (5.3) published for 45 days or more. information is made available participation of various
documents
OPIC provides the project summaries Comments received will be publicly to affected communities stakeholders.
which identify the rationale for reflected in the final version of EIS. and stakeholders for transparent • Relevant countries are required to
designating the project as Category A, (216.7 (c), 22 CFR 216) decision-making. actively publish draft, final and
environmental and social standards to If public hearings are held, draft • The borrower shall provide the updated versions of documents
be used in EIA and the location for Environmental Impact Statements to following environmental and such as EIA / IEE, environmental
local access to environmental and social be discussed should be made social information to the affected and social management plans,
project information. OPIC also posts on available to the public at least communities: Objectives, nature, resettlement plans and ethnic
its website detailed project summaries 5 fifteen (15) days prior to the time of scale, and period of activities group development plans.
for a period of not less than 40 days the public hearings, and a notice pertaining to the proposed project. • In addition, it is required to
before Category A projects are will be placed in the Federal Potential risks and impacts as well disclose the results of
presented for approval. (5.5) Register giving the subject, time and as mitigation measures, Process of environmental and social
OPIC also prepares and discloses place of the proposed hearings. stakeholder participation and monitoring during the project
project summaries which contain (216.8(b), 22 CFR 216) grievance-redress mechanisms. implementation or construction
environmental and social information • The borrower is responsible to period.
for non-Category A projects. These provide relevant environmental • About the method of information
project summaries are posted on and social information in a timely disclosure, disclosure on a website
OPIC’s website for a period of not less manner, at an accessible location, is assumed.
than 30 days prior to execution of the and in a form and language(s) (Excerpt from 4.Principles)
OPIC Agreement.(5.8) understandable to the project • The related country shall ensure
・If the Project is screened as Category affected people and other that relevant information about
A, Applicants are required to submit an stakeholders.(38 to 40) environmental or social issues is
ESIA and a Baseline Audit for public made available in a timely

1
As a USAID safeguard policy, ADS is defined in compliance with Code of Federal Regulations (CFR): https://gov.ecfr.io/cgi-bin/ECFR. In addition, the environmental procedures of USAID are described in CFR in CFR Title 22. Foreign Relations, Chapter II. Agency for International
Development, Part 216. Environmental Procedures. These are regarded as documents that show the procedure of substantial environmental impact assessment of USAID. There are other ADSs related to gender equality and climate change risk management for USAID programs and
projects, but here we will list the ADS on environmental procedures as SGP as a representative one.
2
China Banking Regulatory Commission (CBRC) ‘Green Credit Guidelines (GCG)’ (2012): Guidelines for promoting green credit, applied to policy banks in China, commercial banks, rural cooperative banks, and rural credit unions.
3
The Export-Import Bank of China 'White Paper on Green Finance' (2016): A white paper summarizing the policies and procedures of China's Export-Import Bank's green finance (http://cms.eximbank.gov.cn/upload/accessory / 20172/20172 201624516937087. pdf)
4
Information disclosure case by OPIC: https://www.opic.gov/opic-action/all-project-descriptions
5
It includes information of major environmental and social risks and impacts of the project, mitigation measures, means for meeting application criteria, information on local environmental and social monitoring by OPIC, and information on consultation with affected people.
6
Information disclosure case by Korea Eximbank:https://www.koreaexim.go.kr/site/program/board/basicboard/list?menuid=002002004006&boardtypeid=460#

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disclosure on the OPIC website in manner, in an accessible place,


English. At a minimum, the Applicant and in a form and language(s)
is required to provide a local language understandable to affected people
translation of the executive summary of and to other stakeholders through
the ESIA (and Baseline Audit) and project formation and
make the summary available to Project implementation stage.(7.2)
Affected People in a format that is
readily understandable and tailored to
meet the information needs of them.
(5.18)
・Applicants are required to prepare and
implement an Environmental and Social
Action Plan (“ESAP”) and ESAPs are
required for all Category A projects.
These documents need to be made
public in accordance with OPIC’s
disclosure requirements. (3.14)
・Applicants are required to provide
periodic reports to Project Affected
Persons. This report needs to include
implementation status of any ESAP and
Remediation Plan, other issues, changes
and mitigation measures. (5.20)
3 Category • MCC will screen all projects • Projects that fall under Category • Projects, programs or activities • The borrower shall complete a • It was impossible to confirm • The specific content of the
Classification based on environmental and Prohibited Projects (Appendix B) involving the following are screening form for categorization • GCG’s Article 11 mentioned that category classification is not
Method social impacts, sector and site are excluded first. Moreover, OPIC exempt from these procedures: during the initial stages of project “Banking institutions shall defined and the project will be
location. The screening process categorizes projects based on International disaster preparation and submit it to Korea develop client environmental and categorized according to
will be done by referring to the OPIC’s three factors of (1) the assistance; Other emergency Eximbank as early as possible. social risk assessment criteria environmental and/or social laws
OECD Common Approaches potential impacts within a project’s circumstances; and • Korean Eximbank categorizes into (client E&S risk rating standard).” or guidelines of its government.
and the practices of the WB. Area of Influence in the absence of Circumstances involving categories A, B and C based on the • There is no specific description in Environmental and social
(4.2) any required mitigation, (2) the exceptional foreign policy type of project, location, White Paper. considerations procedures are
• The categories are divided into Applicant’s capacity to effectively sensitivities. (216.2(b), 22 CFR sensitivity and scale, expected size conducted in line with domestic
A, B, C, D. (classification manage the environmental and 216) and content of risks, and estimated laws of the borrowers. (para 1, 6.1
criteria are almost the same as social risks and impacts and (3) the • Except as noted above, the impacts (classification criteria are Pre-construction Stage)
JICA GL. Category D is FI in potential role of third parties in following applies if all new almost the same as JICA GL).
JICA GL.) (4.2) achievement of successful projects, programs and • Categories A and B require the
• Appendix C lists the examples outcomes. (2.5) activities conducted by USAID implementation of ESIA or IEE,
of projects with the potential to • In addition, projects that include are to be carried out and respectively, however, ESIA and
cause significant negative the following factors that raise significant changes or IEE are not required for category C
environmental impacts due to environmental and social risks are extensions are made. projects.
their type, location, sensitivity classified into Category A or • Projects that are not subject to
and scale. Special Consideration: those IEE and EIA. (216.2(c), 22
projects that discharge high levels CFR 216): Technical support
of contaminants (including mainly implemented by
Greenhouse Gases); in the absence USAID.
of adequate pollution controls, as • Projects normally having a
well as those projects that are significant impact on the
considered high risk in the absence environment. (216.2(d)、22
of sound environmental and social CFR 216)
management, projects with large-
scale development, significant
reductions in priority ecosystem
services and places of social value,
projects in places with historically

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PAPs and human rights concerns,


projects in places with historically
concerns in workers' human rights.
Examples of these categories of
projects are provided in Appendix
A.(2.5)
• OPIC categorizes all projects and
subprojects as Category A, B, C or
D (classification criteria are almost
the same as JICA GL. Category D
is FI in JICA GL). OPIC may
apply an additional classification
of Special Consideration 1 to
projects that have heightened
potential for adverse project-
related social risks related to the
involvement of or impact on
Project Affected People including
Workers. (2.6)
4 Referred • The MCC Environmental • It adopts IFC PS and sector • ADS Chapter 204, a USAID • The EDCF policy is not intended • It was impossible to confirm. • NEDA Project must comply with
International Guidelines (August 2010) guidelines in the environmental and SGP, is prepared in accordance to impose mandatory requirements • GCC’s Article 21 mentions that the laws, standards, policies, and
standard, and policy is formulated based on social review process. (1.5) with "22 CFR 216". (ADS and provides guidance to “The banking institutions shall plans of the borrower country.
(Whether it refers the OECD common approach • Applicants must meet the 204.1) borrowers. The Korean Eximbank make promise in public that • Internationally accepted standards
to an and international principles requirements of the IFC • No special international will take into account variables appropriate international practices - International standards, treaties,
international including the Equator Principles Performance Standards.(2.9) standards are referenced in such as the host country context, or international norms will be and declarations should also be
organization or in use by international ADS Chapter 204 and 22 CFR the scale and complexity of project followed as far as such overseas applied as appropriate.
some commercial banks. 2162. impacts, and the associated cost- projects are concerned, so as to • If there arises the matter(s) that is
international • MCC will only support projects benefit considerations, as well as ensure alignment with good not specified in this guideline,
standard as JICA that meet the requirements of those of project performance. (1) international practices.” However, NEDA may use internationally
GL do). IFC PS. • A proposed project must comply it does not mention any specific accepted standards which are
• MCC may provide guidance to a with the borrowing country’s international standards. agreeable between NEDA and the
host country as may be environmental and social • There is no specific description in borrower.(5.5)
advisable in light of requirements, and may refer to White Paper.
international standards, such as internationally recognized
the Environmental, Health, and standards, when appropriate. If the
Safety Guidelines of the WB relevant requirements of the
Group or World Health borrower’s country regulations
Organization guidelines and and laws are more stringent than
standards for implantation of the the requirements of the EDCF SGP
program. or internationally recognized
(Excerpt from 2. Sources of Policy; standards, it is required that the
Applicability of Guidelines) project may comply with more
stringent requirements. (18)
• Where any MDBs or financial
institutions are supporting the
project, Korea Eximbank may

1
OPIC Environmental and Social Policy Statement (January 2017) 2.6: Special Consideration projects are considered to have heightened potential for adverse project-related social risks associated with the involvement of or impact on Project Affected People including Workers. Projects
may be classified as Special Consideration based on an assessment of the severity of possible social risks, and their relevance to a project. Key risk factors that are taken into consideration may include:
- Industry or sector: labor-intensive industries or sectors that are statistically more likely to infringe upon Labor Rights.
- Regional vulnerabilities: projects in countries (i) with a documented history of Labor Rights issues, (ii) having recently experienced conflict associated with Project Affected People, or (iii) with weak or compromised regulatory systems.
- Presence of vulnerable groups: (i) utilization or reliance to a large degree on large pools of sub-contracted, unskilled, temporary, and/or migrant Workers, including within the supply chain; (ii) project risks or impacts that fall disproportionately on Project Affected People who,
because of their particular circumstances, may be disadvantaged or vulnerable, or (iii) sectors in which there is a high risk for the use of forced labor or child labor.
- Significant adverse impacts: (i) projects anticipated to have adverse impacts on a significant numbers of Workers, or (ii) projects that by their nature or footprint could cause or be anticipated to cause (or be complicit in) significant adverse Human Rights impacts.
2
However, in USAID’s Sector Environmental Guidelines (which is a supplemental document for the SGP), international standards such as IFC’s are referred.

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agree to the application of their


environmental and social policies
and procedures to the project,
provided that Korea Eximbank is
satisfied that they are consistent
with the EDCF SGP.(19.)
5 Socially  As one examples of Appendix  One of the elements classified as  Within ADS, gender equality  There is no provision for the ・It was impossible to confirm. GCG ・There is no specific description.
vulnerable C, “project areas of importance "Special Consideration" is when and women's empowerment are definition of socially vulnerable, and White Paper have no description
groups, or special for indigenous peoples or other there is a vulnerable group affected listed, and it is required to other than seeking the participation on the matter.
considerations vulnerable groups” is by the project. (2.6) integrate gender perspectives in of socially vulnerable groups in
mentioned.  One of the social factors to be Country Development stakeholder consultations. ( 43-
・There is no specific description considered in ESIA is "individuals Cooperation Strategies, project 45)
concerning the definition and and groups that may be particularly design, implementation, etc.  Indigenous peoples may be
consideration of the socially vulnerable because of gender, and to carry out gender analysis particularly vulnerable when
vulnerable groups other than the poverty or other factors". (3.10) for that purpose. (ADS 205.3.1) project activities include
1
above. commercial development of the
 There is no specific description knowledge and cultural resources
concerning the definition and of indigenous peoples, physical
consideration of the socially displacement from their traditional
vulnerable other than the above. lands, and commercial
development of natural resources
that would adversely affect their
livelihood. In these projects, the
borrower will seek the consent of
affected Indigenous Peoples
communities.(32‐40, Appendix 2)
6 Response to ・There is no specific description ・A desk based climate ・Climate risk management guidance ・There is no specific description. ・It was impossible to confirm. GCG ・There is no specific description.
climate change regarding the response to climate vulnerability/impact assessment will be is prepared. Quantitatively assessing and White Paper have no description
(Estimates of change. conducted by utilizing publicly climate risk is difficult, so risks will about the matter.
GHG emissions, (Note: MCC is working on Climate- available tools and databases such as be evaluated as low, moderate or
emissions Resilient development as part of the WB Climate Change Knowledge high. (p.8, Chapter 201, Mandatory
thresholds for MCC's support policy, not within Portal.(8.2) Reference for ADS) 3
which estimates SGP) 2 ・OPIC has committed to reduce the ・There are no stipulations on the
are required, Direct Greenhouse Gas Emissions estimation of GHG emissions, the
consideration of associated with projects in OPIC’s emission thresholds for which
alternatives with active portfolio by 30 percent over a ten estimation is required, the
lower GHG year period (June 30,2008 – September examination of alternatives with
emissions, and 30, 2018) and by 50 percent over a lower GHG emissions, and
confirmation of fifteen year period (June 30, 2008 – confirmation of consistency with the
consistency with September 30, 2023).(8.3) borrower’s NDC.
the counterpart In order to achieve the 30 and 50
country's NDC) percent reduction goals, OPIC
establishes an annual transactional cap
for all new projects with significant
Direct Greenhouse Gas Emissions.(8.5)
・As a condition of OPIC support, all
projects that are expected to produce or
currently produce Direct Emissions
exceeding 25,000 metric tonnes of
CO 2eq per year must quantify and

1
Automated Directives System (ADS), Chapter 205 Integrating Gender Equality and Female Empowerment in USAID’s Program Cycle (April 2017): https://www.usaid.gov/sites/default/files/documents/1870/205.pdf
2
https://www.mcc.gov/initiatives/initiative/climate-resilience
3
A Mandatory Reference for Automated Directives System (ADS), Chapter 201 Climate Risk Management for USAID Projects and Activities (April 2017) : https://www.usaid.gov/sites/default/files/documents/1868/201mal_042817.pdf

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annually report to OPIC the Direct


Emissions from their Project. As a
condition of OPIC support and
consistent with the requirements of
Performance Standard 3 of IFC,
Applicants also shall quantify the
significant indirect emissions (outside
project site) associated with off-site
production of electricity used by the
Project.(8.14)
・There is no description regarding
consistency with GHG emissions and
NDC in consideration of alternative
proposals.
7 Rules on ・Implementing entities will be Applicants are required to carry out ・Conduct consultations in the local ・ It requests the borrower to ensure ・It was impossible to confirm. ・NEDA requires the borrower country
Meaningful expected to incorporate timely, Meaningful Consultation with PAPs. country early in the preparation of information disclosure to affected ・ GCG Article 11 mentioned that to engage in meaningful consultation
Participation of participatory, and meaningful public ・In Appendix D, “Meaningful the EIA and before the impact people and stakeholders and “Banking institutions shall establish with local stakeholders during the
Stakeholders consultation in the development of Consultation” is defined as follows: A assessment is completed and the participation in the decision making sufficient, effective stakeholder Project’s preparation and
ESIAs, and associated EMPs. (5. process that (1) begins early in the project is approved. (216.6 (e) process, especially by affected people communication mechanisms” but there implementation phases, and
Public Consultation and Disclosure) project preparation stage and is carried (1), CFR 216) throughout the project cycle. Also, is no provision for meaningful monitoring phases in a manner
out on an on-going basis throughout the reflect the opinions from them in the participation. commensurate with the risks to, and
project life cycle; (2) provides timely ・It is encouraged to provide project. (14、16、38,39、40、41、 ・ There is no specific description in impacts on, those affected by the
disclosure of relevant and adequate reasonable notification to the 43、44) White Paper. Project. NEDA encourages the
information that is understandable and affected persons as feasible, to ・ Consultation with stakeholders borrower country to prepare minutes of
readily accessible to Project Affected ensure public participation, and to including affected people in the impact their meetings after such consultation.
People; (3) is undertaken in an review and incorporate their assessment process is necessary.(22) (7.1)
atmosphere free of intimidation or comments in the process of ・The borrower shall identify concerned
coercion; (4) is gender inclusive and environmental and social impact stakeholders and develop
responsive, and tailored to the needs of assessment.(ADS 204.3.4 a.(4)) communication mechanisms to
disadvantaged and vulnerable groups; ・There is no special description or facilitate dialogue among relevant
and (5) enables the incorporation of all definition of meaningful stakeholders. The borrower will also
relevant views of affected people and participation. develop and implement a participation
other Stakeholders into decision mechanism tailored to the
making, such as project design, characteristics and interests of the
mitigation measures. affected people. The participation
mechanism may include special
measures to enable meaningful
participation of vulnerable groups. (43)

Source: Respective SGPs as shown below and the footnote

List of Website Links for Reviewed SGPs


 Millennium Challenge Corporation (MCC) (USA):MCC Environmental Guidelines (August 2010)
https://www.mcc.gov/resources/doc/environmental-guidelines
 Overseas Private Investment Corporation(OPIC)(USA):Environmental and Social Policy Statement (January 2017)
https://www.opic.gov/sites/default/files/files/final%20revised%20ESPS%2001132017(1).pdf
 United States Agency for International Development (USAID) (USA):Automated Directives System (ADS), Chapter 204 Environmental Procedures (February 2013)
https://www.usaid.gov/sites/default/files/documents/1865/204.pdf
 United States Agency for International Development (USAID)(USA):Title 22, Code of Federal Regulations, Part 216 (22 CFR 216)
https://www.usaid.gov/our_work/environment/compliance/22cfr216
 EDCF / KEXIM(Korea):EDCF Safeguard Policy (2016):
https://www.edcfkorea.go.kr/site/homepage/menu/viewMenu?menuid=005001006003
 CEXIM(China):information is not disclosed to the public
 NEDA(Thailand):Environmental and Social Safeguards Guidelines (January 2019)

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3.6 Japan's Treaty Ratification

Table below shows the major international treaties ratified or not ratified by Japan related to
environmental and social considerations. In the case where the other country has not ratified the
treaty, but it was ratified by Japan, and with respect to the treaties that Japan has not ratified,
attention needs to be paid to the response.

Table 3-23 Status of Ratification of International Treaties Related to Environmental and Social
Considerations
Official Name/Abbreviation or
No. Overview
common name
I. Treaties Ratified
Environment
1 Convention on Biological Entered into Force: 1993 Ratification Year: 1993
Diversity Number of Parties: 194 countries, EU and Palestine (As of December 2018)
Article 1. Objectives
( 1 ) Conservation of biodiversity
( 2 ) Sustainable use of components of biodiversity
( 3 ) For the purpose of fair and equitable sharing of the benefits arising out of
the utilization of genetic resources
2 Cartagena Protocol on Entered into Force: 2003 Ratification Year: 2004
Biosafety Article 1 OBJECTIVE
(Cartagena Protocol) The Protocol focuses on transboundary migration in particular and is at a
sufficient level in the area of safe transport, handling and use of Living Modified
Organisms (LMOs) that may adversely affect biodiversity conservation and
sustainable use.
3 The Convention on Wetlands of Entered into Force: 1975 Ratification Year: 1980
International Importance Number of Parties: 170 countries (As of December 2018)
especially as Waterfowl Habitat Wetlands such as wet field, marshes and tidal flats bring up diverse organisms,
(Ramsar Convention) and are especially important as waterfowl habitats. However, wetlands are likely
to be targets for development such as landfill and reclamation, and the need to
stop their destruction has come to be recognized. Some wetlands cross borders,
and many of the water birds cross the regions regardless of the border, so
international efforts are required. Therefore, to promote the conservation of
wetlands that are internationally important as water bird habitats and the animals
and plants that inhabit and grow there, and to promote the appropriate use of
wetlands (also commonly referred to as “wise use”) the Convention was adopted
at the International Conference on the Conservation of Wetlands and Waterfowl
held on February 2, 1971, in Ramsar, a town on the coast of the Caspian Sea,
Iran (effective on December 21, 1975) .
4 Convention on International Entered into Force: 1975 Ratification Year: 1980
Trade in Endangered Species of Number of Parties: 182 countries, EU (As of December 2018)
Wild Fauna and Flora The Washington Convention (CITES: Convention on the International Trade of
(Washington Convention) Endangered Species of Wild Fauna and Flora) aims to protect wild animals and
plants by the exporting and importing countries work together to regulate the
international trade of wild fauna and flora.
5 Protocol of 1997 to amend the Entered into Force: 2005 Ratification Year: 2005
International Convention for the Number of Parties: 30 countries (As of February 2007)
Prevention of Pollution from An international treaty and its protocol to stipulate the prohibition of dumping
Ships of 2 November 1973, as and releasing controlled substances, the duty of reporting, and procedures for the
modified by the Protocol of 17 purpose of preventing marine pollution caused by ship navigation and accidents.
February 1978 (Marpol Treaty)
6 Basel Convention on the Entered into Force: 1992 Ratification Year: 1993
Control of Transboundary Number of Parties: 181 countries, EU and Palestine (As of May 2015)
Movements of Hazardous The "Basel Convention on the Control of Transboundary Movements of
Wastes and their Disposal Hazardous Wastes and their Disposal" was formulated, which stipulates
international frameworks and procedures for the regulation of transboundary
movement of certain hazardous wastes.
At the Conference of the Parties to the Basel Convention on May 10, 2019 on
the International Movement of Harmful Waste held in Geneva, Switzerland, a

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Official Name/Abbreviation or
No. Overview
common name
draft treaty amendment was adopted to include dirty plastic waste as an import
and export regulatory target.
7 Stockholm Convention on Entered into Force: 2004 Ratification Year: 2004
Persistent Organic Pollutants Number of Parties: 178 countries, EU (As of September 2014)
(Stockholm Convention) For the purpose of protecting human health and the environment from persistent
organic pollutants, (1) Prohibition of production, use and import / export of 18
substances (substance listed in Annex A) such as polychlorinated biphenyl
(PCB), (2) Restriction on production, use, import and export of 2 substances such
as DDT (substance listed in Annex B), (3) Reduction of four unintentionally
generated dioxins (substance listed in Annex C) are stipulated for proper
management of waste in this convention.
8 Montreal Protocol on Entered into Force: 1989 Ratification Year: 1989
Substances that Deplete the The main regulatory measures defined in this Protocol are as follows.
Ozone Layer (1) Setting the elimination schedule of Ozone Depleting Substances (ODS)
(Article 2 A to I)
(2) Regulation of trade with non-party to this protocol countries (prohibition or
restriction of import and export of controlled substances, etc.) (Article 4)
(3) Evaluation and reexamination of regulatory measures based on the latest
information on science, environment, technology and economy (Article 6)
(4) Setting the phasing schedule hydrofluorocarbons (HFC) used as a
chlorofluorocarbons (CFC) substitute (J Article 2) (added in Protocol revision of
2016)
9 United Nations Framework Entered into Force: 1994 Ratification Year: 1994
Convention on Climate Change Number of Parties: 197 countries / organizations
The ultimate goal of the Convention is to achieve stabilization of atmospheric
greenhouse gas concentrations at levels where human activities do not bring
about a dangerous impact on the climate system.
Kyoto Protocol to the United Entered into Force: 2005 Ratification Year: 2005
Nations Framework Convention Number of Parties: 192 countries / organizations
on Climate Change (Kyoto (The framework until 2020, the framework after 2020 is the Paris Agreement)
Protocol) It imposes on Annex I countries (the developed countries) of the Framework
Convention to reduce greenhouse gas emissions by a fixed numerical value in
the ratio of 1990 in five years from 2008 (Annex B). On the other hand, it does
not impose reduction obligations on non-Annex I countries (developing
countries).
Paris Agreement Adoption Year: 2015 Ratification Year: 2016
Number of Parties: 185 countries / organizations
An international framework on climate change that sets out measures to combat
global warming after 2020. Participating countries have the obligation to create
and submit and maintain Nationally Determined Contribution (NDC), and have
the duty to take domestic measures to achieve the purpose of the reduction
targets.
Cultural property
10 Convention Concerning the Entered into Force: 1975 Ratification Year: 1992
Protection of the World Cultural Number of Parties: 193 countries, EU (As of February 2018)
and Natural Heritage The aim of this convention is to establish an international cooperation and
(World Heritage Convention) assistance system to protect and preserve cultural and natural heritage as a world
heritage for all humanity and protect them from the threat of damage and
destruction.
Labour
11 ILO Declaration on Adopted at the ILO General Assembly on June 18,1998, in order to respond to
Fundamental Principles and the challenges of globalization.
Rights at Work This declaration is also referred to as "core labor standards (CLS) of the ILO,
one of the most important basic documents of the ILO alongside ILO Charter
and the Declaration of Philadelphia.
Globalization is a factor in economic growth, and although economic growth is
a prerequisite for social progress, it is a fact that it alone is not sufficient to secure
social progress. It needs to be accompanied by a common value-based social
ground principle to enable all stakeholders to demand an equitable distribution
of wealth that has contributed to their creation.
12 Convention concerning Forced Entered into Force: 1932 Ratification Year: 1932
or Compulsory Labour(No.29) Number of ratified countries: 178 countries
A treaty intended to abolish the use of all forced labor in the shortest possible

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time. Forced labor refers to all labor that is forced by the threat of punishment
and that is not voluntarily offered.
13 Convention concerning Entered into Force: 1948 Ratification Year: 1966
Freedom of Association and Number of ratified countries: 155 countries
Protection of the Right to Workers and employers shall have the right to establish and to join organizations
Organise (No.87) of their own choosing without previous authorization. Workers' and employers'
organizations (including unions) shall have the right to draw up their
constitutions and rules, to elect their representatives in full freedom, to organize
their administration and activities and to formulate their programmes. The public
authorities shall refrain from any interference which would restrict this right or
impede the lawful exercise thereof. Workers' and employers' organizations shall
not be liable to be dissolved or suspended by administrative authority. Workers'
and employers' organizations must respect the laws of the country when
exercising these rights. On the other hand, the laws of that country must not be
such as to violate the security set forth in this Convention.
14 Convention concerning the Entered into Force: 1951 Ratification Year: 1953
Application of the Principles of Number of ratified countries: 166 countries
the Right to Organise and to Workers shall enjoy adequate protection against acts of anti-union
Bargain Collectively (No.98) discrimination such as make the employment of a worker subject to the condition
that he shall not join a union or shall relinquish trade union membership or cause
the dismissal of or otherwise prejudice a worker by reason of union membership
or because of participation in union activities outside working hours or, with the
consent of the employer, within working hours.
15 Convention concerning equal Entered into Force: 1953 Ratification Year: 1967
remuneration for men and Number of ratified countries: 173 countries
women workers for work of Equal remuneration for men and women workers for work of equal value refers
equal value (No.100) to rates of remuneration established without discrimination based on sex. The
Convention provides a definition of remuneration which includes the ordinary,
basic or minimum wage or salary and any additional emoluments whatsoever
payable directly or indirectly, whether in cash or in kind, by the employer to the
worker and arising out of the worker's employment
16 Convention concerning Entered into Force: 1973 Ratification Year: 2000
Minimum Age for Admission to Number of ratified countries: 171 countries
Employment (No.138) The Convention, which revises the 10 Conventions in the field adopted in the
past, defines the minimum age for employment as the end of compulsory
education age of 15 years, under any circumstances it must be followed in order
to abolish child labor and improve working conditions for young workers.
17 Convention concerning the Entered into Force: 2009 Ratification year: 2007
promotional framework for Number of ratified countries: 47 countries
occupational safety and health Promote the development of a preventive health and safety culture by
(No.187) establishing a national plan on occupational safety and health and placing
occupational health and safety at the top of the national policy agenda. This
convention also promotes a safer and healthier working environment through
precautionary measures.
Indigenous people
18 United Nations Declaration on The UN General Assembly in 2007 adopted the “Declaration on the rights of
the Rights of Indigenous Indigenous Peoples”. The 46 Article of Declaration, which covers the following,
Peoples (UNDRIP) defines a wide range of indigenous rights.
• Self-determination rights (indigenous peoples have the right to autonomy or
self-government, and they can maintain their distinct manner of economic, social
and cultural development)
• The right not to be subjected to forced assimilation
• Right to seek restitution or compensation for land or resources
• Right to seek autonomy
• Right to practice cultural and religious practices
• Right to educate and receive education in their own languages
• The right to use land and resources that have traditionally been connected
Human Rights
19 Universal Declaration of It was adopted by the 3rd UN General Assembly on December 10, 1948. In order
Human Rights to respect and secure human rights and freedoms, it declared "a common
standard of achievement for all peoples and all nations."
20 Convention on the Rights of the Entered into Force: 1990 Ratification year: 1994
Child Number of Parties and Regions: 196 (As of February 2016)

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The Convention on the Rights of the Child defines children under the age of 18
as "children" and extends the rights defined in the International Human Rights
Code for children. This convention provides detailed and specific matters that
are necessary from the perspective of respecting and securing children's human
rights. It was adopted by the 44th UN General Assembly in 1989 and entered
into force in 1990. Japan ratified this convention in 1994 .
21 Convention on the Elimination Entered into Force: 1981 Ratification Year: 1985
of All Forms of Discrimination Number of Parties: 189 countries
against Women (CEDAW) For the purposes of this Convention, “discrimination against women” refers to
gender-based distinction, exclusion or restriction, in the political, economic,
social, cultural, civil or any other field. Discrimination also refers to any effect
or purpose to harm or invalidate women (whether married or not) to recognize,
exercise and enjoy human rights and fundamental freedoms on a basis of equality
with men.
22 International Convention on the Entered into Force: 1969 Ratification Year: 1996
Elimination of All Forms of Number of Parties: 179 countries
Racial Discrimination International Convention on the Elimination of All Forms of Racial
(ICERD) Discrimination mainly focuses on taking policies without any form of racial
discrimination without delay in any appropriate way, in order to ensure equality
of human rights and fundamental freedoms. It was adopted by the 20th UN
General Assembly in 1965 and entered into force in 1969. Japan joined this
convention in 1995.
23 Convention Relating to the Entered into Force: 1954 Ratification Year: 1981
Status of Refugees Parties have identified that the UN Charter and the Universal Declaration of
(Refugee Treaty) Human Rights have confirmed the fundamental rights and freedoms of human
rights, that the refugee issue is a major concern of the United Nations and amend
and integrate existing international agreements on refugees. Taking into account
the fact that it is desirable to expand its scope of protection, and that the refugee
problem cannot be resolved without international cooperation, and to prevent the
refugee problem from becoming a source of tension among nations, all countries
are hoped to take all necessary measures. Finally, it recognizes the importance
of cooperation between the UN High Commissioner for Refugees and each
country.
II . Treaties not Ratified
Environment
24 Convention on Long-rage Entered into Force: 1979 Number of Parties: 51 (As of September 2012)
Transboundary Air Pollution Establish a framework for the general obligation to limit, reduce and prevent air
pollution, such as long-distance transboundary air pollution.
25 Convention on Environmental Entered into Force: 1991 Number of Parties: 45 (As of September 2012)
Impact Assessment in a To apply domestic environmental impact assessment procedures to other
Transboundary Context countries, and to set up discussions among nations based on the assessment
results.
26 Convention on the Protection Entered into Force: 1992 Number of Parties: 39 (As of September 2012)
and Use of Transboundary To define that parties should take measures to prevent pollution of the waters of
Watercourses and International other bordering countries.
Lakes
27 Convention on the Entered into Force: 1992 Number of Parties: 40 (As of September 2012)
Transboundary Effects of Define the duty to establish a disaster prevention system for industrial accidents
Industrial Accidents that have an impact across borders.
28 Convention on Access to Entered into Force: 2001 Number of Parties: 46 (As of September 2012)
Information, Public Establish international standards to secure citizens' access to information,
Participation in Decision- participation in decision-making, and the right to exercise judicial means in the
Making and Access to Justice in process of formulation and implementation of environmental policies.
Environmental Matters
29 International Convention for the Entered into Force: 2017 Number of Parties: 36 (As of December 2012)
Control and Management of Regulate and control of ballast water (seawater) and sediments loaded for safe
Ships' Ballast Water and navigation of ships, and harmful aquatic organisms and pathogens contained in
Sediments ballast water which are transported to the discharge destination, and prevent the
danger to the environment, human health and property.
Labour
30 Convention concerning the Entered into Force: 1959 Number of Parties: 174 (January 2013)
Abolition of Forced Labour A treaty that reinforces and supplements the 1930’s Forced Labor Convention
(No. 29).

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Each member of the ILO which ratifies this Convention undertakes to suppress
and not to make use of any form of forced or compulsory labour:
(a) as a means of political coercion or education or as a punishment for holding
or expressing political views or views ideologically opposed to the established
political, social or economic system;
(b) as a method of mobilizing and using labour for purposes of economic
development;
(c) as a means of labour discipline;
(d) as a punishment for having participated in strikes;
(e) as a means of racial, social, national or religious discrimination.
31 Convention concerning Entered into Force: 1960 Number of Parties: 172 (As of January 2013)
Discrimination in Respect of It is one of the basic conventions, which is centered on the labor field but has the
Employment and Occupation nature of a more general human rights security treaty.
This treaty stipulates that no discrimination should be taken in terms of
employment and occupation. The term “discrimination treatment” means “any
distinction, exclusion or preference made on the basis of race, color, sex,
religion, political opinion, national extraction or social origin, which has the
effect of nullifying or impairing equality of opportunity or treatment in
employment or occupation” but discrimination, exclusion, or preference for
certain tasks that require special conditions are not considered discrimination
treatment.
32 Convention concerning the Entered into Force: 1979 Number of Parties: 45 (As of January 2013)
Protection of Workers against To specify that Parties should take legislative action to prevent occupational
Occupational Hazards in the hazards in the work environment due to air pollution, noise and vibration, and to
Working Environment Due to protect workers from such hazards.
Air Pollution, Noise and
Vibration (No. 148)
Indigenous People
33 Convention concerning Entered into Force: 1991 Number of Parties: 23
Indigenous and Tribal Peoples Governments shall have the responsibility for developing, with the participation
in Independent Countries of the peoples concerned, coordinated and systematic action to protect the rights
of these peoples and to guarantee respect for their integrity. No form of force or
coercion shall be used in violation of the human rights and fundamental freedoms
of the peoples concerned, including the rights contained in this Convention. The
government shall consult the peoples concerned, through appropriate procedures
and in particular through their representative institutions, whenever
consideration is being given to legislative or administrative measures which may
affect them directly. In addition, important provisions such as development
process and related people's rights, employment and employment conditions,
vocational training, handicrafts / rural industries, social security, sanitation,
education, land, etc. are included. The rights of ownership and possession of the
peoples concerned over the lands which they traditionally occupy in this
Convention also affects the work of the UN.
Source: Prepared by the JICA Study Team based on the following information.
1. Convention in general: Ministry of Foreign Affairs site "treaty data search" https://www3.mofa.go.jp/mofaj/gaiko/treaty/
2. Convention on the labour and indigenous peoples: ILO Office in Japan site "Convention List (numerical order, including the Protocols) "
https://www.ilo.org/tokyo/standards/list-of-conventions/lang--ja/index.htm
3. Convention Not Ratified: "International Convention list of which our country is not yet ratified (As of January 2013) National Diet Library
Research and Legislative Review Office March 2013"

3.7 Achievements and Challenges of JICA 's Capacity Development Programs

JICA invites officials of executing agencies of JICA projects in developing countries to Japan once
a year for 2types of JICA Knowledge Co-Creation Program. The Programs are “Practice of
Environmental and Social Considerations for Investment Project Financing” aimed at strengthening
the practical ability of the staff of project proponents etc. involved in environmental considerations,
and “Public Participation, Consensus Building and Resettlement in Public Works Project,” focusing

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on social considerations. Participants, during the period of stay in Japan for about 3 to 4 weeks,
learn about JICA GL and conduct on-site observations of environmental and social considerations
in Japan, conduct discussions and group works among participants gathered from different countries,
trainers and host organizations received those participants, and acquire knowledge and skills
necessary for environmental and social considerations practices in infrastructure development
projects.

In addition, JICA Academy provides trainings, pre-service training, and theme training for JICA
staff, and capacity-building trainings for consultants involved in environmental and social
considerations named “environmental and social considerations for practitioners and consultants”
are provided every year. Also, JICA holds pre-service international cooperation training prior to the
oversea assignment of JICA experts. Through these programs, various stakeholders are provided
with an opportunity to deepen their understanding of the importance and contents of the JICA GL.

The table below shows the results of the environmental and social considerations related trainings
conducted by JICA from 2011 to 2018. Since 2011, approximately 600 to 1,100 persons shave
participated in the trainings for JICA staff, officials from developing countries, consultants, etc. In
the field surveys and questionnaires, the executing agencies have many requests for participating in
such trainings concerning environmental and social considerations. Although training in Japan is
desirable, there were opinions that JICA may consider to offer the trainings in the host country or
neighboring countries so that more practitioners can attend, as the number of participants is limited
if it is held in Japan.

As for the participants of the JICA environmental and social considerations practical trainings, 120
officials of executing agencies participated in FY2011, 84 in FY2012, 100 in FY2013, 145 in
FY2014, 101 in FY2015, 203 in FY2016, 142 in FY2017, and 53 in FY2018. In addition, 27 out of
100 target projects in this review study confirmed the participation of project personnel in these
trainings.

Delhi Metro Rail Corporation (DMRC), which is the executing agency of Delhi Metro Project, is
engaged in consulting services in some metro projects in India. In the field survey of this study, they
expressed their wish to have a regular workshop with other metro corporations in India to discuss
and solve environmental and social issues by sharing their own experiences and learnings of
advanced environmental mitigation measures in Japan.

Table 3-24 Results of Environmental and Social Considerations Training


Number of Participants (persons)
Types of Training
FY2011 FY2012 FY2013 FY2014 FY2015 FY2016 FY2017 FY2018
Training for JICA
staff (introductory 327 323 484 285 388 502 661 352
training etc.)
Developing
country officials 120 84 100 145 101 203 142 53
(trainees etc.)

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Number of Participants (persons)


Types of Training
FY2011 FY2012 FY2013 FY2014 FY2015 FY2016 FY2017 FY2018
Capacity Building
40 97 74 126 79 80 109 203
of Consultant
Other 250 164 226 116 52 122 206 181
Total 737 668 884 672 620 907 1,118 789
Source: Prepared by JICA Study Team based on JICA Performance Evaluation Report

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CHAPTER 4 DRAFT DISCUSSION POINTS FOR REVISION OF JICA GL

Discussion points are summarized in Table 4-1based on the analysis results described in Chapter 2
and 3.

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Table 4-1 Draft Discussion Points for Revision of JICA GL


Reference: Survey Items Survey Results Discussion Points
Items of Current Including Recommendations from WG on Review of Operation Background and Reasons for Discussion Points (Draft)
JICA GL
Preface
Ⅰ.Basic Matters
1.1 Policy 1. Summarize the Japanese Government’s policies such as “Cabinet 1. Japanese Governmental Policy and Global Trend in International Development Cooperation
1.2 Objectives decision on the Development Cooperation Charter” and trend of 1.1 Japanese Governmental Policy
1.3 Definitions international development such as SDGs. 【The Development Cooperation Charter】
1.4 Basic Principles ・ The Development Cooperation Charter shows the philosophy of Japan’s development cooperation including ODA. It aims to Response to the
Regarding contribute to peace and prosperity through non-military cooperation, promoting human security, supporting self-help efforts as governmental policies
Environmental and well as dialogue and collaboration based on Japan’s experience and expertise. As implementation principles, Japan will pay due such as the
Social attention to the impact of development on the environment and climate change, and implement development cooperation in an Development
Considerations environmentally friendly manner. The Charter also states that Japan will pay attention to the social impact, while making efforts to Cooperation Charter
promote participation of wide-ranging stakeholders in every phase of development cooperation, with a view to reducing and the Promotion of
inequalities and in consideration of the socially vulnerable groups such as children, persons with disabilities, the elderly, ethnic Quality Infrastructure
minorities and indigenous peoples. Investment.

【Promotion of Quality Infrastructure Investment】


・ The Government of Japan is promoting quality infrastructure investment with the aim to export Japanese quality infrastructure in
order to meet global demand for infrastructure, especially in emerging countries. This is to provide quality infrastructure that
secures economic efficiency with low life-cycle costs, inclusiveness, safety and resilience, and sustainability. It also aims to
apply good standards such as Guidelines for Environmental and Social Considerations for its implementation. Moreover, the
Government has the policy to further accelerate procedures in order to roll out its development cooperation strategically.

【G7 Ise-Shima Principles for Promoting Quality Infrastructure Investment】


・ G7 Ise-Shima Summit was held in 2016 and “G7 Ise-Shima Principles for Promoting Quality Infrastructure Investment” was
announced as one of the attached documents of G7 Ise-Shima Leaders’ Declaration. In the Principal three actions addressing the
social and environmental impacts, it is described that quality infrastructure investment must consider the social and environmental
impacts of infrastructure projects and duly address such impacts by applying social and environmental safeguards that are in line
with international good practices as reflected in the most relevant standards including those of existing MDBs.

1.2 Global Trend in International Development Cooperation


【SDGs】
・ SDGs consist of 17 goals described in the 2030 Agenda for Sustainable Development which was adopted by the UN General Response to the global
Assembly in September 2015. JICA has formulated the policy for all the 17 goals and committed to contributing to achieving the trend such as SDGs and
SDGs. JICA has a policy to play a key role in achieving 10 goals for the SDGs: i.e. zero hunger, health, education, the Paris Agreement
water/sanitation, energy, economic growth, industry/infrastructure, sustainable cities, climate actions, and forests & biodiversity.
Through complying the JICA GL that promote meaningful participation of project stakeholders, JICA believes that it will adhere
to the principle of “No one will be left behind”. Compliance to JICA GL also enable JICA to support international efforts to
achieve SDGs, which are key milestones to realize a sustainable society, and complement or reinforce them.

【The Paris Agreement】


・ At the COP21 of the UNFCCC, the first international climate agreement was adopted that brings all ratified nations into a
common ambitious efforts to reduce GHG emissions and combat climate change. It aims to strengthen the global response to the
threat of climate change by keeping a global temperature rise this century well below 2°C above pre-industrial levels and to
pursue efforts to limit the temperature increase even further to below 1.5°C. The Agreement also states that "in order to achieve
the long-term temperature goal […], Parties aim to reach global peaking of greenhouse gas emissions as soon as possible,
recognizing that peaking will take longer for developing country Parties, and to undertake rapid reductions thereafter in
accordance with best available science, so as to achieve a balance between anthropogenic emissions by sources and removals by
sinks of greenhouse gases in the second half of this century, on the basis of equity, and in the context of sustainable development
and efforts to eradicate poverty." Under the Agreement, (1) all parties will prepare NDCs and pursue domestic mitigation
measures to achieve them and continue to submit NDCs every five years with more ambitious targets; (2) all parties will also
report regularly on their activities and the information submitted will undergo a technical expert review, and based on the review;
(3) there will also be a global stocktaking every five years to assess the collective progress towards achieving the purpose of the
Agreement. Japanese Government announced “Actions for Cool Earth 2.0: ACE 2.0” that includes provision of approx. 1.3 trillion
JPY of public and private climate finance to developing countries by 2020.
・ In October 2018, IPCC published a special report on Global Warming of 1.5ºC. The report warns that human activities have
caused approximately 1.0°C of global warming above pre-industrial levels, and the warming is likely to reach 1.5°C between 2030

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Reference: Survey Items Survey Results Discussion Points


Items of Current Including Recommendations from WG on Review of Operation Background and Reasons for Discussion Points (Draft)
JICA GL
and 2052 if the current trend continues. The report urges that rapid and far-reaching transitions in energy, land, urban and
infrastructure (including transport and buildings), and industrial systems (high confidence) is needed and global net anthropogenic
CO2 emissions must reach net zero at around 2050 to limit global warming to 1.5°C.
・ The Japanese government adopted “the long-term strategy under the Paris Agreement” in the Cabinet meeting on June 11, 2019.
The long-term vision sets the ultimate goal of achieving a “decarbonized society” and commits to make ambitious efforts to
achieve it as early as possible in the second half of this century. The vision also states that Japan will take bold measures to reduce
GHGs emissions by 80% by 2050. Japan will create “a virtuous cycle of environment and growth” through business-led disruptive
innovation and implement actions quickly to contribute to the global society and make a bright future, according to the vision.
1.5 Responsibility of (Confirmed through the review of Chapter II and III of JICA GL) 1. Safeguard requirements in equity financing by IFC, ADB, and WB
JICA 1. Confirmation of safeguard requirements in equity financing by
IFC, ADB, and WB. Confirm the responsibility of other donors WB
such as IFC, ADB, etc. for their investment project financing. ・ The Environmental and Social Framework (ESF) launched on October 2018 applies to all Investment Project Financing
comprised of bank loan and guarantees provided through IBRD and IDA. (ESF, WB Environmental and Social Policy for
Investment Project Financing, Footnote 3, OP 10.00) Since the loans to the private sector and equity finance are implemented
through MIGA and IFC, such financings are not included in the scope of WB ESF.

IFC
・ The IFC conducts a variety of investments, including project finances, investments through financial intermediaries, and equity
finance to companies. Regardless of the types, PS are applied to proposed investments that are determined to have moderate to
high environmental and/or social risks, or have the possibility of adverse environmental and/or social impacts (Policy on
Environmental and Social Sustainability, 2012 (hereinafter referred to as “SP”), para3). Paragraph 24 of SP states that “if the
client fails to comply with its environmental and social commitments as expressed in the legal agreements and associated
documents, and if the client fails to reestablish compliance, IFC will exercise its rights and remedies”. In IFC’s policy, there is no
distinction between equity finance and other forms of investment, and as such there are no safeguard-related requirements that
only apply to equity finance.
・ Under the AIP (January 1, 2012), there is no distinction between equity finance and other investments, and there are no
safeguard-related requirements that only apply to equity finance.

ADB
・ The SPS (2009) applies to all investment projects funded by a loan; and/or a grant; and/or other means, such as equity and/or
guarantees. (SPS, para 48) Paragraph 72 of SPS states that “if a borrower/client fails to comply with legal agreements on
safeguard requirements and fails to reestablish compliance by an appeal of corrective measures from ADB, ADB may exercise
legal remedies, including suspension of the project”. There is no distinction between equity finance and other forms of investment
in SPS, and as such there are no safeguard-related requirements that only apply to equity finance.
・ Under the AIP (September 2018), there is no distinction between equity finance and other investments, and there are no
safeguard-related requirements that only apply to equity finance.
1.6 Requirements of (Confirmed through the review of Appendix 1 of JICA GL)
project proponents
etc.
1.7 Covered Schemes 1. Summarize JICA’s cooperation project schemes such as Private 1. JICA cooperation project schemes started after enforcement of the current JICA GL Necessity of inclusion
Sector Investment Finance (PSIF), Small and Medium-sized Enterprise ・ Cooperation project schemes which started after enforcement of the current JICA GL include the PSIF, and Support for Japanese of the Public-Private
(SME) promotion, etc., which were increased after enforcement of the Small and Medium Enterprises (SMEs) and the SDGs Businesses. In addition, commissioned projects from the GCF may be Partnerships (including
current JICA GL. added to the JICA’s cooperation project schemes. The current JICA GL are applied to the PSIF, because it corresponds to the ODA feasibility survey and
Loans to which the JICA GL apply. The Support for SME and the SDGs Businesses do not fall under the “Covered Scheme” on verification survey of
the current JICA GL, while the GL have operationally applied to the feasibility survey and verification survey of the Support for the Support for SME
SME and the SDGs Businesses. Detailed descriptions of each schemes are as follows: and the SDGs
・ PSIF: 24 projects were signed during 2011-2018. They include a wide range of projects such as infrastructure projects of different Businesses) and
scales e.g. industrial park development, port improvement and efficient gas fired power generation, as well as small-scale projects entrusted project from
such as human resource development project, micro-finance project, coffee value chain enhancement project, and Asia climate the Green Climate Fund
partner fund project. Environmental categories of these projects cover a wide range from A to C, and FI too. within the covered
・ The Support for SME and the SDGs Businesses: In principle, this scheme has two types of projects: i.e. “SME support type” schemes of the JICA
targeting small and mid-sized companies and “SDGs Business support type” targeting large-sized companies. The “SME support GL.
type” has three support menus: promotion survey, feasibility survey and verification survey, while the “SDGs business support
type” has two support menus: feasibility survey and verification/commercialization survey.
・ As for the three menus of “SME support type”, the service periods range from three months to three years and the maximum
amount of support service ranges from 8.5 to 150 million Yen. In terms of operation, promotion survey is mainly to collect
information and the feasibility is not studied, therefore the JICA GL are not applied to the survey. On the other hand, the JICA GL

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JICA Study for Review of JICA Guidelines for Environmental and Social Considerations February 2020

Reference: Survey Items Survey Results Discussion Points


Items of Current Including Recommendations from WG on Review of Operation Background and Reasons for Discussion Points (Draft)
JICA GL
were applied to the feasibility study and the verification survey in their operation because they include projects that may carry out
feasibility studies or have environmental and social impacts.
・ The main products and technology fields of the feasibility survey and the verification survey are environment/energy, waste, water
purification/water treatment, vocational training/industrial training, welfare, agriculture, health/medical care, education and
disaster prevention/disaster control. Of the 18 projects of the feasibility survey adopted in the first semester of FY2018, four
projects were classified as Categories B and 14 projects were classified as Category C. On the other hand, of the 15 projects of the
verification survey adopted at the same period, one project was classified as category B and 14 projects were classified as
Category C.
・ The “Support for SDGs Businesses” is the scheme that was newly established in July 2018, and the JICA GL were applied to it in
operation because it includes projects that may carry out feasibility studies or have environmental and social impacts. The
“Support for SDGs Businesses” replaced Feasibility Survey for SDGs Business and Collaboration Program with the Private
Sector for Disseminating Japanese Technology, which were former schemes and were not cooperation projects covered by the
JICA GL, however, the JICA GL were practically applied to them. The Feasibility Survey for SDGs Business adopted in the first
half of 2018 were all classified as Category C, while the Collaboration Program with the Private Sector for Disseminating
Japanese Technology adopted at the same period were all classified as Category C.
・ JICA became an accredited entity of an international organization GCF in 2017. Therefore, it is assumed that JICA would be
entrusted the GCF’s projects based on the Article 13 (3) of the Act of the Incorporated Administrative Agency-Japan International
Cooperation Agency in future. Currently, project proposal is being prepared for submission to the GCF, and adoption of a project
has not been completed. JICA is considering that the JICA GL would be applied to the projects entrusted by GCF.

Recommendation from the working group meeting for reexamination of 2. The outline of “SME support type” of the SME Partnership and the SDGs Business Model Formulation projects (former the
JICA GL Operation programs for supporting overseas expansion of SMEs) is described in item 1. above. Based on the recommendation at the time of
【Applicability of GL to feasibility study and other study for PPP operation of review, it is stated in the FAQ about JICA GL that the Environmental and Social Considerations Guidelines apply to
projects】 Preparatory Study for PPP Infrastructure Project, programs for supporting overseas expansion of SMEs (SME ODA F/S and SME
2. As for the Preparatory Survey for PPP infrastructure project and Verification Survey).
SME promotion assistance for overseas investment, summarize the
scheme contents and its relevance to the GL. 3. As stated in item 1 above, the promotion survey of “SME support type” of the SME Partnership and the SDGs Business Model
3. To clearly mention that the SME promotion survey is not subject to Formulation projects is mainly for information collection and the feasibility is not studied. Therefore, it is not covered by the JICA
the GL in practice since the main purpose of the survey is to collect GL. On the other hand, JICA has a policy that any proposals for feasibility survey and verification survey that may have
the information. In addition, as for the SME feasibility survey and significant negative impacts on the environment and society would not be selected.
the verification survey, to clearly indicate that the projects that
would have significant negative environmental and social impacts,
that means Category A projects, will not be implemented.
4. Summarize change of the business environment such as promotion 4. Change of the business environment after enforcement of the current JICA GL
and speedup of infrastructure investment, increase of co-financing 【Promotion of Quality Infrastructure Investment】
with international financial institutions, etc., after enforcement of ・ The Government of Japan was promoting quality infrastructure investment with the aim to export Japanese high-quality
the current GL). infrastructure in order to meet global demand for infrastructure, especially in emerging countries. This is to provide quality
infrastructure that secures economic efficiency with low life-cycle costs, inclusiveness, safety and resilience, and sustainability. It
is also aimed to apply high-quality standards such as Guidelines for Environmental and Social Considerations for its
implementation. Moreover, the Government has a policy to further accelerate the procedure in order to develop the cooperation
strategically.
・ G7 Ise-Shima Summit was held in 2016 and “G7 Ise-Shima Principles for Promoting Quality Infrastructure Investment” was
announced as one of the attached documents of G7 Ise-Shima Leaders’ Declaration. In the Principal 3 addressing actions on the
social and environmental impacts, it is described that quality infrastructure investment must consider the social and environmental
impacts of infrastructure projects and duly address such impacts including by applying social and environmental safeguards that
are in line with international best practices as reflected in the most relevant standards including those of existing MDBs.

【Co-financing】
Suitability of
・ Every year, approximately 10 co-financing projects are implemented with international financial institutions.
introduction of common
・ The WB Environmental and Social Policy for Investment Project Financing (hereinafter referred to as “Environmental and Social
approach to
Policy”), which sets out the mandatory requirements that apply to the Bank stipulates that the Bank will cooperate with other
co-financing projects
multilateral or bilateral funding agencies and the Borrower in order to agree on a common approach, when the Bank is jointly
financing a project with the agencies. A common approach for the assessment and management of environmental and social risks
and impacts of the project will be acceptable to the Bank, provided that such an approach will enable the project to achieve
objectives materially consistent with the ESS 1-10, after understanding the safeguard policies of the co-financer.
・ ADB SPS stipulates that ADB will make efforts to collaborate with the borrower/client and co-financiers to adopt a single social
and environmental assessment and planning process and unified safeguard documentation, consultation, and disclosure

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Final Report
JICA Study for Review of JICA Guidelines for Environmental and Social Considerations February 2020

Reference: Survey Items Survey Results Discussion Points


Items of Current Including Recommendations from WG on Review of Operation Background and Reasons for Discussion Points (Draft)
JICA GL
requirements to satisfy the safeguard principles and requirements of ADB and of the co-financiers. (SPS, para70)
1.8 Measures Taken 1. Summarize cases which applied “measures taken in an emergency” 1. Cases applied “Measures Taken in an Emergency”
in an Emergency (Categorization, judgement criteria of “emergency,” measure on ・ There were no projects to which “Measures Taken in an Emergency” as per the JICA GL were applied among the reviewed
involvement of the advisory committee, information disclosure, projects. It was confirmed that there had been a total of seven projects (Technical Cooperation for Development Planning) for
monitoring, follow-up activity, etc.) which emergency measures were applied after the enforcement of the JICA GL. In all the projects, detailed design study was
skipped, but preliminary scoping (which is usually carried out in detailed design study) was carried out in the main study. In all
cases, the application of “Measures Taken in an Emergency” was reported to the Advisory Committee for Environmental and
Social Considerations before the main survey.
Project Name Category Scheme
Project for the Comprehensive Flood Management Plan for the Chao B Technical Cooperation for Development
Phraya River Basin, Kingdom of Thailand Planning
Jarar valley and Shebele Sub-basin Water Supply Development Plan, B Technical Cooperation for Development
and Emergency Water Supply, Ethiopia Planning
The Project for Enhancing Community Resilience against Drought in B Technical Cooperation for Development
Northern Kenya, Kenya Planning
Rural Resilience Enhancement Project, Ethiopia B Technical Cooperation for Development
Planning
Sustainable Smallholder Irrigation Development and Management in B Technical Cooperation for Development
Semi-Arid Lands Project, Kenya Planning
Project on Rehabilitation and Recovery from Nepal Earthquake, B Technical Cooperation for Development
Recommendation from the working group meeting for reexamination of Nepal Planning
JICA GL Operation Project for Development of Regional Disaster Risk Resilience Plan in B Technical Cooperation for Development
【Confirmation of environmental and social considerations in case of Central Sulawesi Planning
emergency】 2. There are no projects categorized as “Category A” that applied Measures Taken in an Emergency after enforcement of the current
2. It is desirable that Category A projects are not applicable to Guidelines.
“Emergency Measures” described in Section 1.8 under the JICA
GL unless life-saving or humanitarian assistance is urgently 3. Projects to which Measures Taken in an Emergency was applied after enforcement of the current JICA GL were seven projects of
needed. Technical Cooperation for Development Planning. The information of the projects are disclosed in JICA’s website.
3. In the section 1.8 of the JICA GL, it is stated that “an emergency (https://www.jica.go.jp/english/our_work/social_environmental/id/emergency.html)
means a case that must be dealt with immediately, such as
restoration after natural disasters or post-conflict restoration, when 4. Under the current JICA GL, there are no cases to which Measures Taken in an Emergency was applied other than Technical
it is clear that there is no time to follow the procedures of Cooperation for Development Planning scheme.
environmental and social considerations mentioned in the
guidelines”. It is desirable that classification criteria are clarified 5. When to which Measures Taken in an Emergency was applied to the Technical Cooperation for Development Planning, detailed
by describing which projects were classified as emergency projects design study was skipped. However, scoping and preparation of Terms of Reference (TOR) on environmental and social
so far. considerations, which were normally prepared during the detailed design stage, were implemented during the main study stage.
4. In the past operation, Section 1.8 of the JICA GL was applied to Among the seven projects, Project on Rehabilitation and Recovery from Nepal Earthquake included the implementation of
the Technical Cooperation (M/P) projects for natural disasters. In priority emergency projects, however no environmental and social impacts were identified during the main study stage. In
case that it is applied to the other project scheme, it is desirable to addition, there were no cases that unanticipated impacts on environmental and social aspects were pointed out after the completion
explain the procedure to be implemented to the Advisory of the Technical Cooperation for Development Planning.
Committee.
5. If environmental and social considerations are simplified for an
emergency response, post-project monitoring or any follow-up
measure needs to be taken appropriately.
1.9 Dissemination 1. Summarize records which JICA explained about the JICA GL to 1. JICA’s explanation about the JICA GL to project proponents etc. and the contents thereof.
project proponents etc. and its contents. ・ It was confirmed that JICA explained about the JICA GL to the project proponents etc. and the proponents agreed to comply with
the JICA GL in all the 100 targeted projects. Staff of the project proponents etc. (120 in FY2011, 84 in FY2012, 100 in FY2013,
145 in FY2014, 101 in FY2015, 203 in FY2016, 142 in FY2017 and 53 in FY2018) participated in the training on the
environmental and social considerations conducted by JICA. It was also confirmed that staff members of 28 projects out of the
total 100 projects participated in these trainings.
1.10 Advisory (Confirmed through the review for “2.7 Advice of the Advisory
Committee of Committee for Environmental and Social Considerations”)
Environmental and
Social
Considerations

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Final Report
JICA Study for Review of JICA Guidelines for Environmental and Social Considerations February 2020

Reference: Survey Items Survey Results Discussion Points


Items of Current Including Recommendations from WG on Review of Operation Background and Reasons for Discussion Points (Draft)
JICA GL
II. Process of Survey Items, Recommendation from WG on Review of Operation Survey Results, Background and Reasons of Discussion Points Discussion Points
Environmental and (draft)
Social
Considerations
2.1 Information 1. Confirm status of information disclosure by JICA (Categorization, 1. Information disclosure by JICA
Disclosure final report, environmental and social considerations reports, ・ In all of the reviewed projects, all the documents related to environmental categorization, final reports of the preparatory survey,
results of environmental review, monitoring result) environmental and social considerations documents and results of environmental review that need to be disclosed as per the
2. Confirm status of information disclosure by project proponent etc. requirements of JICA GL were disclosed in JICA’s website. (Private sector partnership projects are not applicable as prior survey
(Disclosure place, term, language, etc. on environmental and social is not carried out for this type of project.)
consideration reports and monitoring results)
3. Confirm status which JICA encouraged project proponents etc. to 2. Information disclosure by recipient countries
disclose the information. ・ As for 41 Category A projects, excluding 1 E/S loan project which environmental and social considerations documents are to be
4. Confirm if the third party requested information disclosure and its prepared, and 4 projects for Technical Cooperation for Development Planning, it was confirmed that environmental and social
correspondence considerations documents were disclosed for all 36 projects by the project proponents. In addition, regarding the methodologies of
5. Confirm correspondence to the information which is prohibited to public disclosure, disclosure of environmental and social considerations documents at the project proponent and provision of a
disclose copy of these documents are the most common process (36 projects), and the documents are also disclosed on the project
proponent’s website in 14 projects of them. As for the used language, when the main document is written in English, the executive
summary was often prepared in a local language. Regarding 42 Category B projects, excluding 4 projects which disclosure
process by the project proponent were confirmed, in many cases, there was no agreement between JICA and the project proponent
for disclosure or there was no country regulation which requires the project proponent to prepare environmental and social
considerations documents. In the case the project conducted the stakeholder meeting and prepared the environmental and social
considerations documents, it is confirmed that the environmental and social considerations documents were disclosed at the
stakeholder meeting.

3. JICA’s encouragement to project proponents etc. to disclose the information.


・ Out of 82 projects (excluding 8 projects for Technical Cooperation for Development Planning and 10 Category C projects that are
not applicable), it was confirmed that JICA and project proponents etc. agreed at the time of appraisal to disclose environmental
monitoring results in 45 projects (and among them, it is agreed to disclose social monitoring results in 19 projects). In all projects,
JICA explained about the information disclosure based on the JICA GL at the time of environmental review stage. The review
study confirmed that JICA encouraged project proponents etc. to disclose the information in all projects; however, JICA could not
agree on disclosure of monitoring result with some project proponents etc. The reasons are mostly related to the national
legislation or policy and include that disclosure is not required under the national law, or project proponents etc. decided to follow
their own disclosure policy. The number of projects in which information disclosure was agreed was increasing since the
enforcement of the JICA GL. Among the ODA loan projects for which loan agreement was signed in FY2010, there were only
four projects in which disclosure of environmental monitoring results was agreed while the monitoring was to be done in 36
projects, and there were only four projects in which disclosure of social monitoring results was agreed while the monitoring was
to be done in 15 projects. On the other hand, in FY 2017, it was improved to 20 out of 38 projects agreed for disclosure of
environmental monitoring and 12 out of 14 projects for disclosure of social monitoring.

4. Request of information disclosure from third parties and how such requests were handled
・ The request for information disclosure from third parties was made to JICA in two projects (Nos. 4, 83). Both projects were the
subject of JICA’s objection procedures.

5. Information which is not allowed to disclose


・ In all projects, JICA has not disclosed such information mistakenly and obtained the consent from the project proponent in
advance when disclosing related information.

【Additional Survey Items】Safeguard provisions of the WB etc. regarding information disclosure Status of EIA report to
・ In the WB Environmental and Social Policy, it is stipulated that for the high-risk projects and the substantial risk projects, reports be disclosed before the
on environmental and social risks and impacts of the Project based on the environmental and social impact assessment including environmental review
EIA reports are disclosed before the Bank appraisal. These reports can be disclosed at the draft stage. There is no requirement in (draft EIA or approved
terms of the duration of the disclosure period. version)
・ ADB stipulates that draft environmental impact assessment reports shall be disclosed at least 120 days before Board consideration Necessity of disclosure
for environment category A projects. (SPS, para 53) of environmental permit
certificate before the
・ The disclosure of EIA reports is not a mandatory requirement for IFC. Instead, IFC will summarize all necessary information in
environmental review
the ESRS and disclose it. ESRS will be published for 60 days or more prior to the board meeting for Category A projects and 30
Disclosure period of
days or more in other projects.
EIA report

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Final Report
JICA Study for Review of JICA Guidelines for Environmental and Social Considerations February 2020

Reference: Survey Items Survey Results Discussion Points


Items of Current Including Recommendations from WG on Review of Operation Background and Reasons for Discussion Points (Draft)
JICA GL
・ In the current JICA GL, it is described that for Category A projects, JICA discloses the following prior to its environmental
review: (1) EIA reports and environmental permit certifications, (2) RAPs for projects that will result in large-scale involuntary
resettlement, and (3) IPPs for projects that will affect indigenous people. In addition, it is stipulated that JICA discloses EIA
reports 120 days prior to signing loan agreement. (GL 3.2.1, (1), 2) JICA currently discloses approved EIA reports based on this
policy, but this creates a challenge for projects. Since JICA proceed to the environmental review only after the EIA reports are
disclosed which authorities already approve, any safeguard-related measures not covered by the EIA but required by JICA GL
must be agreed on top of EIA. In such a case, the project proponents etc. need to comply not only with EIA but also with
additional agreements with JICA, which may create confusion and undermine effective implementation of safeguard measures.
These cases were observed in three projects (Nos. 24, 28, 29).

【Additional Survey Items】Disclosure of monitoring and supervision results Necessity of disclosure


・ In the JICA GL, it is required that JICA discloses the results of monitoring conducted by project proponents etc. on its website to of the monitoring
the extent that they are made public in project proponents, etc. (3.2.2.7) results
・ ADB’s SPS stipulates that ADB discloses monitoring reports on its website. (SPS, para71)
・ There are no provisions concerning the disclosure of environmental and social monitoring results under the safeguard policies and
the information disclosure policies of the WB, the EBRD, the IDB and the AfDB.
・ According to the WB Access to Information Directive/Procedure, the “aide-mémoire” of operational missions may be made
publicly available if both the WB and the country/borrower agree. (Access to Information Directive/Procedure, para.3a, revised
April 2019)
2.2 Categorization 1. Summarize results of environmental categorization and its reason. 1. Environmental Categorization and its rationale
2. Summarize the recategorized project and its reason
3. Summarize categorization justification in case there was a doubt on ・ Significant gaps between the result of environmental categorization and its rationale were not confirmed in all 100 projects.
the categorization from the third party.
4. Confirm the submission status of the screening format. 2. Changes in Environmental Categorization
・ In three projects (Nos.25, 27, 63)out of the 100 projects, the environmental category was changed. The reasons for change were:
[No.25] the components related to the engineering service of the power plant were excluded from the project (A→C); [No.27] a
large-scale resettlement was confirmed when M/P and F/S were revised in consideration of the flood damage that happened after
F/S was initially prepared by the project proponent (B→A), [No.63] the components related to construction of the final waste
disposal site were excluded from the project (B→C).

3. Relevance of environmental category


・ It was confirmed that the relevance of the categorization was questioned with two projects by the third parties. They are: Project
No.36 Infrastructure Development Project in Thilawa Area (Phase I) in Myanmar, and Project No.83 Support for Agricultural
Development Master Plan for Nacala Corridor in Mozambique.

4. Submission status of the screening format


・ Screening was conducted based on the screening form or adequate information from project proponents etc. in all 100 projects.

【Additional Survey Items】Provision related to project categorization in the WB ESF, etc.


・ In WB OP 4.01, the proposed projects were classified into one of four categories: A, B, C, FI, depending on type, location, Necessity to refer to
sensitivity, and scale of the project and the nature and magnitude of its potential environmental impacts. As per the new new project
Environmental and Social Policy, the proposed projects are classified into one of four categories: High Risk, Substantial Risk, categorization (High
Moderate Risk or Low Risk, taking into account relevant issues shown below. Risks are reviewed on a regular basis and any Risk, Substantial Risk,
change will be disclosed on the Bank’s website. Moderate Risk, Low
 The type, location, sensitivity and scale of the Project; Risk) introduced in the
 The nature and magnitude of the potential ES risks and impacts; Environmental and
 The capacity and commitment of the Borrower to manage such risks and impacts in a manner consistent with the ESS Social Policy (which is
(Among the WB ESF, requirements that should be met by the project to be implemented and the Borrower); about requirements of
 The environmental and social mitigation measures and outcomes, depending on the specific project and the context; and the WB) which is a part
 The nature of the mitigation and technology being proposed; governance structures and legislation; and considerations of ESF
relating to stability, conflict or security.
・ In order to comply with each ESS, the requirements for the Borrowers are set that are appropriate to the nature and scale of the
project and proportionate to the level of environmental and social risks and impacts. (Environmental and Social Policy, para 6)
・ It is not mentioned in ESF that it is necessary to consider the environmental and social impacts of the associated facilities when
determining risk classification. (Environmental and Social Policy, para 6)
・ In the ADB’s SPS, it is stipulated that a project’s category is determined by taking into consideration direct, indirect, cumulative,

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JICA Study for Review of JICA Guidelines for Environmental and Social Considerations February 2020

Reference: Survey Items Survey Results Discussion Points


Items of Current Including Recommendations from WG on Review of Operation Background and Reasons for Discussion Points (Draft)
JICA GL
and induced impacts of the projects, but not stipulated to consider the environmental and social impacts from the associated
facilities. (SPS, para 50)
・ In the IFC’s SGP, it is stipulated to consider the potential environmental and social risks of the project in its categorization, but no
reference is made to “associated facilities”.

【Additional Survey Items】Category B projects


・ Out of 100 reviewed projects, 42 projects are Category B projects. In terms of project scheme, they can be divided into ODA Loan
(12 projects), ODA Grant (18 projects), Technical Cooperation (3 projects), Technical Cooperation for Development Planning (3
projects), and SME partnership and others (6 projects). Among them, 9 projects of Technical Cooperation, Collaboration with
private partners and others were relatively small-scale (e.g. dispatching experts or installation equipment) and no involuntary
resettlement was expected, thus environmental and social impacts were expected to be limited. As for Technical Cooperation for
Development Planning projects, due to its nature of the examination of the higher-level plan, the scale of the project presented in
the plan and its impacts varied within a certain range. On the other hand, concerning 12 Category B Loan projects, average project
cost was about 15 billion Yen and the scale was relatively large, such as rehabilitation of road and airport. In some projects,
involuntary resettlement was expected although its scale was not large. As for 18 Category B Grant projects, the average cost of
projects was about 2.5 billion Yen, the scale of the projects was relatively small compared to the ODA Loan projects, and so were
the project impacts. Category B is the most diverse category that includes various scales of projects, and thus there are
considerable variations in terms of project impacts and risks.
2.3 Impacts to be (Confirmed through the review of Appendix 1 of JICA GL)
Assessed
2.4 Consultation with 1. Confirm records of consultation between JICA and project 1. Record of public consultation
Local Stakeholders proponents etc.
・ In the current JICA GL, it is stipulated that the project proponents etc. disclose scoping drafts, which consist of project names,
2. (Record of consultation other than the above will be confirmed
countries, locations, project outlines, environmental categorizations and its reasons, alternative analysis, impacts, and contents.
through the review of Appendix1, Social Acceptability of JICA
Project proponents etc. also consult with local stakeholders reflecting stakeholder analysis for Category A projects, and if
GL.)
necessary, for Category B projects. JICA supports project proponents etc. in doing so in order that they incorporate the results of
such consultations into their environmental and social considerations surveys (GL3.1.2.6).
・ Among the 100 projects, it was confirmed that stakeholder consultation meetings for EIA/RAP were held at the environmental
review stage in 69 projects. (31 projects are not applicable. They are: 10 Category C Projects, 7 FI Projects, 9 Category B projects
for which impacts are likely to be very small (e.g. rehabilitation within the existing facilities or project identification studies of
SME Partnership projects, and 5 projects of Technical Cooperation for Development Planning in which stakeholder consultations
had been held at the master plan planning.) Of these 69 projects, implementation of stakeholder consultation at the scoping stage
was confirmed in all Category A projects excluding 3 projects (36) in which JICA did not implement the feasibility study and
project proponents etc. prepared EIA. The same was confirmed in 11 out of 32 Category B projects for which stakeholder
consultations was conducted as per the requirements of JICA GL.

【Additional Survey Items】Provisions related to stakeholder engagement in the WB ESF Necessity to refer to the
・ The WB ESS 10 “Stakeholder Engagement and Information Disclosure” applies to all projects supported by the Bank through provisions about
Investment Project Financing. (ESS 10 para 4) In ESS 10, it is stipulated that “stakeholder” refers to individuals or groups who (a) Stakeholder
are affected or likely to be affected by the project; or (b) may have an interest in the project. (ESS 10 para 5) Engagement Plan
・ It is stipulated that the Borrower will develop and implement a SEP. In the SEP, the following contents are described: stipulated in ESS 10
identification of project-affected parties and other interested parties, the timing and methods of engagement with stakeholders, the
range and timing of information provided, the method of announcement of the meeting, the venue, report of the results of the Note: ESS is a part of
meeting and the grievance mechanism in detail. A draft SEP will be disclosed as early as possible, and before project appraisal. ESF and indicates the
(ESS 10, para 13) requirements to be met
・ The Borrower will undertake a process of meaningful consultation. Meaningful consultation is a two-way process in which by the borrower and the
stakeholders can express their opinions on project risks, etc., and the Borrower also considers and responds to them. (ESS 10 para project
21, 22)
・ The Borrower will propose and implement a grievance mechanism. A grievance mechanism includes different ways in which
users can submit their grievances, a log, transparent process, an appeals process when resolution of grievance has not been
achieved. (ESS 10 para 26, Annex 1 para 1-3)
・ In the IFC PS 1 “Assessment and Management of Environmental and Social Risks and Impacts”, it is stipulated that the client will
develop and implement a SEP that is scaled to the project risks and impacts and development stage, and be tailored to the
characteristics and interests of the Affected Communities (para 27). The SEP may include project description, identification of
stakeholder, engagement program and description of grievance redress mechanisms. (GN 1 para 98) In addition, the client will
disclose relevant project information to the affected communities. The information to be disclosed includes the SEP. (para 29,
footnote 26)

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JICA Study for Review of JICA Guidelines for Environmental and Social Considerations February 2020

Reference: Survey Items Survey Results Discussion Points


Items of Current Including Recommendations from WG on Review of Operation Background and Reasons for Discussion Points (Draft)
JICA GL

【Additional Survey Items】Provision of MDBs safeguard requirement regarding stakeholder consultation


・ ADB: The SPS stipulates that ADB is committed to working with borrowers/clients to put meaningful consultation processes into
practice, and borrowers/clients will conduct the stakeholder engagement activities in a manner commensurate with the risks to
and impacts on affected communities. On the other hand, development and implementation of SEP are not required. (SPS,
para54)
2.5 Concern about 1. Confirm special consideration on information disclosure and 1. Consideration on information disclosure and consultation with local stakeholders taken for cooperation projects in countries and
Social Environment consultation with local stakeholders taken for cooperation projects areas affected by conflict or where basic freedoms, including freedom of expression and the right to receive legal remedy, are
and Human Rights in the countries and areas affected by conflict or where basic restricted
freedoms, including freedom of expression and the right to receive ・ It was confirmed that none of the 100 projects take place in such countries or areas.
legal remedy, are restricted. ・ According to the Office of the United Nations High Commissioner for Human Rights, etc., it is pointed out that threats and attacks
to persons who advocate for defending human rights are becoming international concerns.
2. Confirm any special attention paid to human rights of socially 2. Confirmation of special attention paid to human rights of socially vulnerable groups
vulnerable groups It was confirmed that plans on considerations to socially vulnerable groups were developed in 60 out of the 100 projects. (This was not
applicable in 10 Category C Projects, 7 FI, and 18 projects in which no impacts to vulnerable groups were identified (e.g.
implementation of improvement of the existing facilities, or collaboration with private partners). See Annex 1 Socially Vulnerable
Groups for more details.
【Additional survey items】Provisions related to human rights and socially vulnerable groups in the WB ESF
・ In the WB ESF, A Vision for Sustainable Development declares at the beginning and focuses on empowering all people to
participate in the development process, promoting equality and nondiscrimination, and considering vulnerable individuals and
groups. Through these policies, the WB has committed consideration for human rights declared in the Universal Declaration of
Human Rights.

【Additional survey items】Scope of consideration on human rights


・ It is described in the Japan’s Development Cooperation Charter that people who are liable to be vulnerable include children,
women, persons with disabilities, the elderly, refugees and internally-displaced persons, ethnic minorities, and indigenous peoples. Consideration of human
rights and its scope,
・ It is described in section 2.5 “Concern about Social Environment and Human Rights” in the JICA GL that vulnerable social groups
necessity of adding
include women, indigenous peoples, persons with disabilities, and minorities. In addition, it is also described in section 2.3
socially vulnerable
“Impacts to be Assessed” that items related to human rights to be considered include vulnerable social groups such as poor and
groups as a target group
indigenous peoples, gender, and children’s rights, but here is no description about refugee, internally displaced people and the
for such considerations
elderly.

【Additional survey items】Guiding Principles on Business and Human Rights: Implementing the United Nations “Protect, Respect and
Remedy” Framework
・ UN Special Representative John Ruggie, who was assigned as a special representative on issue of human rights, transnational
corporations, other business enterprises, proposed a framework on business & human rights “Protect, Respect and Remedy“ to the
UN Human Rights Council in June 2008. The framework is called as “Ruggie Framework”, resting on three pillars: “the state duty
to protect against human rights abuses by third parties, including business”, “the corporate responsibility to respect human rights”
and “greater access by victims to effective remedy”. In order to implement the framework, “Guiding Principles on Business and
Human Rights: Implementing the United Nations ‘Protect, Respect and Remedy’ Framework” (hereinafter referred to as “Guiding
Principles”) was developed and endorsed by the UN Human Rights Council in June 2011.
・ The Japanese Government committed to follow the Guiding Principles and announced that it planned to formulate a National
Action Plan on business and human rights at the UN Forum on Business and Human Rights held in November 2016. According to
the Ministry of Foreign Affairs, the National Action Plan is scheduled to be published in mid 2020.
2.6 Laws, 1. Whether national legislation on EIA and RAP are complied. 1. Compliance with national laws
Regulations and 2. Whether there is any gap between projects and the international ・ Among the 100 projects, EIA approval in line with the national law was required and was obtained in 50 projects. Though 7
Standards of standards such as WB SGP. Category A projects (Nos. 5, 8, 26, 27, 31, 32, 33) were not required to prepare EIA documents or obtain approvals under the host
Reference country’s laws and regulations, it was confirmed EIA reports were prepared in accordance with the requirements of the JICA GL
and approved by a ministry in charge or the project proponent. It was confirmed that EIA reports were prepared by the time of
environmental review in all 20 Category B projects which were subject to EIA under the national law.

2. Deviations from international standards such as WB SGP


・ In the JICA GL, JICA confirms that projects do not deviate significantly from the WB’s SGPs. (GL2.6.3)
・ No major deviation was seen in all the reviewed projects from the requirements of WB’s SGP and other international safeguard
standards. Most projects used EHSG (air, noise, vibration, effluent water, surface water, emission gas), WHO standards (air,
noise, vibration, water quality), ISO standards (vibration), EU standards (air, emission gas, water quality), Japanese standards

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Items of Current Including Recommendations from WG on Review of Operation Background and Reasons for Discussion Points (Draft)
JICA GL
(noise, vibration, effluent water, water quality, air, JIS vibration) as a refence of international emission standards. However, in the
10 projects (Nos. 7, 13, 15, 20, 26, 28, 31, 32, 46, 47), only national standards were used in environmental assessment process.
This is because in these projects, it was confirmed that there is no major gap between national standards and international
standards. Regarding involuntary resettlement, most projects referred WB OP4.12 and the ADB SPS as international standards.
3. Summarize the changes from WB SGP (OPs) to ESF. 3. The changes from WB SGP (OPs) to the ESF Necessity of confirming
3.1 ESF is a comprehensive document consisting of the following documents. no significant deviation
・ A vision for Sustainable Development: it sets out the Bank’s aspirations regarding environmental and social sustainability from the WB ESS
・ The WB Environmental and Social Policy for Investment Project Financing (Environmental and Social Policy): it sets out the (requirement for host
mandatory requirements that apply to the Bank government)
・ ESS: it sets out the mandatory requirements that apply to the Borrower and projects. The contents of ESS 1 to ESS 10 are as
follows:
ESS 1 Assessment and Management of Environmental and Social Risks and Impacts
ESS 2 Labor and Working Conditions
ESS 3 Resource Efficiency and Pollution Prevention
ESS 4 Community Health and Safety
ESS 5 Land Acquisition, Restrictions on Land Use and Involuntary Resettlement
ESS 6 Biodiversity Conservation and Sustainable Management of Living Natural
Resources
ESS 7 Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local
Communities
ESS 8 Cultural Heritage
ESS 9 Financial Intermediaries
ESS 10 Stakeholder Engagement and Information Disclosure

3.2 Major changes are shown as follows:


1) Nine individual policies and procedures on safeguard (OPs, BPs) were integrated into the ESF. ESF includes 10 ESSs which
apply to all projects. Standards added to the ESS that were not included in the former SGPs or were not presented as a stand-alone
policy are Labor and Working Conditions (ESS 2), Community Health and Safety (ESS 4), Financial Intermediaries (ESS 9) and
Stakeholder Engagement and Information Disclosure (ESS 10).
2) Categorization is based on the magnitude of environmental and social impacts in the former safeguard policies, while it is based
on the contents of the project, environmental and social risks of the project and so on in ESF. Environmental and social risks will
be evaluated in an integrated manner, and adaptive actions of proposed project will be taken so that changes or unforeseen
circumstances can be appropriately managed.
3) The new ESF is more aligned with policies of other funding agencies and international good practice, especially those of IFC.
・ It is stipulated in the JICA GL that JICA confirms that projects do not deviate significantly from the WB’s SGP. As the ESF took
effect in October 2018, it is necessary to examine whether assessment of significant gaps between the JICA GL and ESS should be
required or not.
4. Summarize the gap between WB ESF and the current JICA GL 4. The gap between WB ESF and the current JICA GL WB ESS1: Necessity of
・ Major items in the ESS that were changed from the former WB SGP and other international standards are described in each GL referring to the
item. requirements
・ As general items, ESS 1 “Assessment and Management of Environmental and Social Risks and Impacts” requires the Borrowers concerning preparation
to prepare the following documents. of Environmental and
A) Preparation of ESIA: The environmental and social risks and impacts of the project will be assessed. All relevant direct, Social Impact
indirect and cumulative environmental and social risks and impacts throughout the project life cycle will be assessed Assessment report and
including those specifically identified in ESSs 2–10 (ESS 1 para 23-). The social aspect includes workers related to the Environmental and
project (ESS 2) and consideration for surrounding communities (ESS 4). Social Commitment
B) Agreement on ESCP: It is required to prepare a document that summarizes the important points such as mitigation measures Plan
and monitoring plan in ESIA.
・ If the Bank reviews the Borrower’s ES Framework and concludes that the project’s risks and impacts will be appropriately WB ESS1: Necessity of
addressed to achieve objectives materially consistent with the ESSs, so the Borrower can use its ESF (all of or part of), instead of referring to the
ESS. (ESS 1, para 19, 20) requirements
concerning the use of
borrower’s ES
framework
5. Summarize the standards and good practices in the safeguard 5. Standards and good practices in the safeguard policies of the ADB and the IFC, which can be referred by JICA projects Necessity of confirming
policies of ADB and IFC which can be referred by the JICA no significant deviation
projects 5.1 ADB from gap analysis with

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JICA GL
・ The SPS (2009), ADB's SGP, defines the requirements of the ADB, as well as the requirements that borrowers/client to meet, and IFC PS when
it consists of environment, involuntary resettlement, indigenous peoples, and special requirements for different finance modalities. considering equity
investment/loan
5.2 IFC provision to
・ IFC established “International Finance Corporation’s Policy on Social and Environmental Sustainability” and “Environmental and Public-Private
Social Performance Standard (PS)” in 2012. The PS elaborates a set of requirements that are grouped by eight different Partnership projects
topics/issues as indicated in the table below. Compared to the WB ESS, ESS 9 and ESS 10 are not included in the IFC PS, but the
contents are covered in the IFC's Interpretation Note on Financial Intermediaries (which defines the application of the IFC policies
and the PS on environmental and social sustainability to projects of financial intermediaries) and in PS 1, and thus there is no
major difference. As for details of each PS, see the section Appendix 1: Environmental and social considerations required for
intended projects of this table.
PS 1 Assessment and Management of Environmental and Social Risks and Impacts
PS 2 Labor and Working Conditions
PS 3 Resource Efficiency and Pollution Prevention
PS 4 Community Health, Safety, and Security
PS 5 Land Acquisition and Involuntary Resettlement
PS 6 Biodiversity Conservation and Sustainable Management of Living Natural Resources
PS 7 Indigenous Peoples
PS 8 Cultural Heritage
・ IFC also prepared GNs to offer helpful guidance on the requirements contained in the PS.
・ In case of JICA’s PPP (PSIF, preparatory survey (PPP infrastructure projects)), proposed companies usually follow environmental
and social safeguard procedures in accordance with the Equator Principles, and these projects typically refer IFC's PS as an
international standard.

5.3 Environmental, Health, and Safety Guidelines


・ WB EHSG are technical reference documents that contain 1) the general guidelines (General EHSG) that include environmental
standards, emissions standards, mitigation strategies, safety measures, and occupational health and safety, and 2) the
industry-specific guidelines (Industry Sector Guidelines).
・ WB and IFC compare borrower’s standards with those of the EHSG, and apply the stricter one. However, in consideration of
project-specific conditions such as technical and financial constraints of the borrowers, alternative standards may be applied as
long as the purpose of ESS or PS are not impaired and significant impact does not occur. (WB ESS 1, para 18) (IFC PS on
Environmental and Social Sustainability, para 6, 7)
2.7 Advice of the 1. Summarize records of advisory committee meetings. (including 1. Summarization of records of JICA Environmental and Social Considerations Advisory Committee Follow-up on contents
Advisory Committee improvements in its operation and information disclosure.) ・ Meetings of the Advisory Committee were properly held for all 41 Category A projects. additionally agreed
for Environmental 2. Confirm how advices from the advisory committee at the upon at the time of
and Social environmental review stage were incorporated in the projects 2. Confirmation on how advices from the Committee during the environmental review are incorporated in the projects appraisal where the EIA
Considerations ・ Out of the total 557 pieces of advice from the Advisory Committee, 550 pieces of advice suggested revisions/updates of the report was already
Preparatory Survey reports (this include advices for one project in which final report is being prepared taking into account the approved
advices) or confirmation or agreement with the project proponent before appraisal. While most advices were properly taken care
of, the review study identified several advice that poses some challenges to follow (see the next bullet point). Regarding the
remaining 38 pieces of advice, it was confirmed that they were properly addressed during the implementation of the projects.
・ In some cases, the follow-up of the advice was challenging. This is partially because environmental and social consideration
documents such as EIA had already been approved or had been being subject to the official review process when the Advisory
Committee meeting was held at JICA’s environmental review stage. For instance, in three projects (Nos.24, 28, 29), the advice
was not incorporated in the EIA since they were already approved or in the process. In such a case, measures following the advice
was agreed at the time of the project appraisal on top of EIA.
2.8 Decision-making 1. Confirm the status of agreement documents 1. Confirmation of the status of agreement documents
by JICA 2. Whether any cooperation project was suspended based on ・ Agreements between JICA and the project proponents etc. were concluded in all the 100 projects.
agreement documents. 2. Suspension based on agreement
No cooperation projects were suspended based on the non-compliance with the agreements.
2.9 Ensuring (To be confirmed separately through the review of objection
Appropriate procedures.)
Implementation of
and Compliance with
the Guidelines
2.10 Implementation Not applicable. ・ JICA reviewed the operational procedure of the JICA GL in 2015, and prepared FAQs based on the advices of the Advisory

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JICA GL
and Review of the Committee, in order to addresses challenges identified through implementation of the JICA GL. The topics discussed and
Guidelines compiled in the FAQs include “impact of associated facility”, “derivative, secondary, cumulative impacts”, “critical natural
habitats” “significant conversion or significant degradation”, “protected areas that are specifically designated for the conservation
of nature or cultural heritage”, “consideration of environmental and social impacts on ecosystem”, and “stakeholder meeting in
consideration of socially vulnerable groups”.
III. Procedures Survey Items Survey Results Discussion Points
of Environmental Including Recommendations from WG on Review of Operation Background and Reasons for Discussion Points (Draft)
and Social
Considerations
3.1 Preparatory 1. Summarize practices of alternative analyses including “without 1. Analysis of alternatives including “without project” scenario Necessity of including
Study project” scenarios ・ Among the 100 projects, it was confirmed that alternative analysis was examined for all 41 Category A projects. Regarding “zero option” in
2. Confirm implementation records of each procedure in the Category B projects, it was done in 38 projects. Analysis of alternative was not conducted in four exceptional cases such as “without project
preparatory study, such as scoping, EIA/IEE study, information projects taking place within the premise of existing facility (Project Nos.62, 65, 66, 76). scenario” when
disclosure, stakeholder meetings etc. ・ In most Category A projects, “without project” scenario was examined when conducting alternative analysis. As an exception, in conducting alternative
the case of co-financing projects in which EIA report was prepared with the support of MDBs (ADB, AfDB), “without project” analysis
scenario was not examined.
・ Analysis of alternative was done in 79 projects (41 Category A and 38 Category B). The typical patterns of an analysis are as
follows (however, nine projects with limited impacts such as SME support type projects and projects with minor construction
work are excluded from the trend analysis as alternative analysis for these projects were simplified): Comparison of alternative
project sites and routes are most common and was found in 51 projects, followed by project design (34 projects), construction and
operation method (9 projects, out of this, 4 projects focus specifically on construction methods), and the project implementation
schedule (4 projects). In terms of M/P study with Strategic Environmental Assessment (7 projects in total), alternative analysis
was conducted on project sites (4 projects), project design (4 projects), construction and operation methods (1 project) and project
implementation schedule (1 project).
・ Alternative analysis from both economic aspects (e.g. project cost, feasibility, etc.) and environmental and social aspects are
examined for 24 projects. More specifically, analysis on the economics aspect was confirmed in 27 projects, environmental
aspects in 28 projects, and social aspect in 28 projects. Alternative analysis on social aspects, especially land acquisition and
resettlement aspects, were often confirmed. Technical alternatives were analyzed for 25 projects. In addition, it was found that
alternative analysis includes some other aspects such as geography, effectiveness, demands, safety, difficulty to obtain
permissions, the construction period, a flood risk, and consistency with higher level governmental policies.
・ Out of the 90 projects, alternatives analysis was conducted 79 projects in total, namely in 41 Category A projects and in 38
Category B projects excluding 4 projects (Nos.62,65,66,76) which are to be constructed in the premises of the existing facilities
(details are provided in the next section (2)).
・ Out of the 100 projects for review, the alternative project plan were examined for all 41 projects Category A projects. In addition,
the alternative analysis has been conducted with 38 Category B projects except for the ones which are implemented within the
premises of existing facilities (Nos.62, 65, 66, 76). In total, the alternatives have been examined in 79 projects.
・ Methodological pattern observed with 70 projects out of the 79 projects were summarized below. Remaining 9 projects are
excluded from this analysis as alternative analysis was conducted in a simple methodology for (1) the SME support projects are
proposed by the private sector (verification survey/feasibility survey with the private sector for disseminating Japanese
technologies, promoting private sector cooperation and BOP business collaboration project); and (2) technical cooperation
projects accompanied with small scale construction work but limited environmental and social impacts.
・ The examination of alternative project sites/routes are most common in 51 projects. Subsequently, project design alternatives were
considered in 34 projects; alternatives of the construction and operation method were considered in 9 projects (especially, the
construction method was examined in 4 projects); the alternative implementation schedules were considered in 4 projects
(including selection of priority projects in the M/P). As for 7 technical cooperation projects for development planning which
conducted SEA, it was confirmed that alternative project sites and project designs were considered in 4 projects each; and both
alternative construction and operation methods and implementation schedules were examined in one project each.
・ For 31 Category A projects out of 70 projects which conducted alternative considerations, whether alternatives were considered
from economic, social and environmental aspects was reviewed. Alternative analysis from both economic aspects (e.g. project
cost, feasibility, etc.) and environmental and social aspects are examined for 24 projects. More specifically, the alternative analysis
on the economics aspect was confirmed in 27 projects, environmental aspects in 28 projects, and social aspect in 28 projects. The
alternative analysis on social aspects, especially land acquisition and resettlement aspects, were often confirmed.
・ Technical alternatives were analyzed for 25 projects. In addition, it was found that alternative analysis includes some other aspects
such as geography, effectiveness, demands, safety, difficulty to obtain permissions, the construction period, a flood risk, and
consistency with higher level governmental policies.
・ Quantitative alternative analysis was confirmed in 22 projects. It was often observed that the quantitative analysis was partially
conducted because it is not easy to evaluate alternatives quantitatively for all the options. More specifically, alternative

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Items of Current Including Recommendations from WG on Review of Operation Background and Reasons for Discussion Points (Draft)
JICA GL
considerations were often conducted at several sites or routes and at the different planning stages under one project. The limited
availability of existing data for the alternative consideration at the early planning stage is also another challenge for quantitative
evaluation. In addition, there are 2 projects (Nos.32, 34) with which alternative analysis were evaluated quantitatively by
Multicriteria Analysis (MCA) using weighted evaluation parameters and both the quantitative and qualitative data.
・ Alternative analysis was conducted by considering quantitative and qualitative positive effects in 17 projects. For example, the
regional economic effect (including increase in employment), improvement of traffic congestion, easiness for extension,
connectivity with other transportation, improvement of transportation network, safety, EIRR, less travel time, GHG emission
reduction, appropriate treatment of heavy metals, reduction of odour, improvement of water quality, improvement of air quality
and noise due to improved traffic congestion, environmental conservation by improvement construction (e.g. river bank and sand
beach), indirect impact of improved agriculture production by the power generation projects, potential future development, urban
planning potentials were considered as positive effects. Although these positive effects were considered, these positive effects are
both for the alternatives selected and not selected.

2. Implementation of each safeguard procedure during preparatory survey


・ It was confirmed that every procedure required under JICA GL in the preparatory survey was implemented in 67 projects. This
requirement is not applicable for 33 projects as the preparatory study was not conducted.

【Additional Survey Items】Methods of alternative analysis


・ Methods of alternative analysis in SEA stage and in EIA stage are as follows:
1. MDBs
(1) SEA Stage
・ There are no specific requirements about alternative analysis at SEA in the safeguard policies of WB, IFC and ADB, etc.
(2) EIA Stage: Alternative analysis stipulated in the WB ESS, ADB SPS and IFC PS are as follows:
1) WB
 Systematically compares feasible alternatives to the proposed project site, technology, design, and operation-including the
“without project” situation--in terms of their potential environmental and social impacts; and
 Assesses the alternatives’ feasibility of mitigating the environmental and social impacts; the capital and recurrent costs of
alternative mitigation measures, and their suitability under local conditions; the institutional, training, and monitoring
requirements for the alternative mitigation measures.
 For each of the alternatives, quantifies the environmental and social impacts to the extent possible, and attaches economic values
where feasible. (ESS 1, Annex 1 D. Indicative Outline of ESIA, (g))
2) ADB
 Examine alternatives to the project’s location, design, technology, and components and their potential environmental and social
impacts and document the rationale for selecting the particular alternative proposed. Also consider the no project alternative. (SPS,
1. Environmental Safeguards para 3)
 Alternatives will be examined for the proposed project site, technology, design, and operation—including the no project alternative
—in terms of their potential environmental impacts; the feasibility of mitigating these impacts; their capital and recurrent costs;
their suitability under local conditions; and their institutional, training, and monitoring requirements. In addition, the basis for
selecting the particular project design proposed, and recommended emission levels and approaches to pollution prevention and
abatement will be recorded. (SPS, Annex to Appendix 1: Outline of an Environmental Impact Assessment Report, F.)
3) IFC
For those projects with potential significant adverse impacts, the client will conduct a comprehensive environmental and social
risks and impacts assessment, including an examination of technically and financially feasible alternatives. (PS 1, footnote 11,
GN25)

2. Japan
1) EIA Act
・ It is stipulated in the EIA Act of Japan that efforts must be made to include an option of not implementing the proposed project
when assessing different alternatives at the stage of Document on Primary Environmental Impact Consideration (Hairyo-sho1). In
addition, “without project” scenario includes “zero option”, one of the alternatives that can accomplish the objective of the project
without implementing the proposed project. (Ministry of the Environment Working Group regarding technical approach for
environmental impact assessment in the planning stage, Technical Guidance regarding Procedure of Environmental Impact

1
The Ministry of the Environment published a guideline for introducing Strategic Environmental Assessment in 2007. The Guideline applies to mainly type 1 projects as specified in the EIA Act of Japan (Act No. 81 of June 13, 1997) that are large scale and potentially have significant environmental impacts.
SEA is to be undertaken during the planning stage of these projects (considering the location and scale of the project). According to the Environmental Impact Assessment Network (http://assess.env.go.jp/1_seido/1-1_guide/3-1.html), Hairyo-sho is defined as the document describing the results of the
assessment about environmental issues prepared at the stage when the project location and scale are being considered.

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Items of Current Including Recommendations from WG on Review of Operation Background and Reasons for Discussion Points (Draft)
JICA GL
Assessment in the planning stage, March 2013)
The Basic Matters relating to the Guidelines etc. to be Established by the Competent Minister in Accordance with the Provisions
of the EIA Act (The Environment Agency Notification No.87 of December 12, 1997), Amendment; the Ministry of the
Environment Notification Nos. 83 of 2014, June 27, 2014 (Hereinafter referred to as “Basic Matters”)
Section 1, 1
(3) In examining the items in the planning stage, appropriate multiple options concerning location and scale, or structure and
arrangement of building etc. pertaining to Class-1 project (hereinafter referred to as the “multiple plans concerning location etc.”)
shall be prepared as a general rule, and where such multiple plans concerning location etc. are not prepared, the reason thereof
shall be clarified.
Section 1, 3
(3) A statement to the effect that efforts must be made to include an option of not implementing the proposed project, to the extent
that it is feasible, in the multiple plans concerning location etc., shall be specified in the Guidelines for the Selection of the Items
for EIA in the planning stage etc.
・ Under the Basic Matters of Japan, alternative analysis is required concerning a wide range of environmental conservation
measures including those related to structure and location of buildings, environmental conservation facilities, and construction
method etc. at scoping of EIA for individual project (Basic Matters, Section 4.5 (3) A), and comparative examination of multiple
proposals concerning environmental conservation measures is required at the DF/R stage. (Basic Matters, Section 5.2 (5))
2) JICA
・ In the current JICA GL, description of alternative analysis in SEA and EIA are not differentiated. Moreover, the JICA GL do not
explicitly require that “zero option” be included in the assessment of “without project” scenario.

3. Recommendation from the 5th working group meeting for 3.“Without project” scenario: the following is how to consider the option of “without project” scenario.
reexamination of JICA GL Operation ・ Although “without project” scenario (namely a scenario that WB project is not implemented) is considered in the ESIA of the WB
【Alternative analysis】 projects, any other options that would achieve the project objective without the proposed projects are not considered.
It is necessary to clarify interpretations of “without project“ scenarios ・ Similarly, ADB’s projects ESIA considers a scenario where no projects including ADB's projects are implemented, and any other
under the JICA GL . measures that would achieve the project objectives are not considered.
・ In the current JICA GL, different methods of alternative analysis in SEA and EIA are not elaborated. In addition, the JICA GL do
not state clearly whether “without project” scenario should include the zero option.
・ Under the policies of WB and ADB, “without project” scenario does not include the zero option.

【Discussion point raised by the Advisory Committee】


On March 6, 2017, “North East Road Network Connectivity Improvement Project (Phase 3) (Preparatory Survey (ODA Loan))”
“Indicator of evaluation of alternatives and viewpoint of evaluation” was discussed at the WG for the proposed scoping and concluded
as follows:
“So far, there are no methodologies that can be derived from the JICA GL, etc., regarding alternative analysis at the draft scoping stage,
and discussions and selection of indicators for comparison and selection of optimal alternatives are conducted case-by-case basis in
each project. … In addition, the Advisory Committee suggested that alternative analysis should with zero option (to achieve the project
objectives with other measures without implementing the project). In response, the JICA explained that although comparison with the
zero option is desirable, comparison with the “without project” scenario is to be conducted in accordance with the JICA GL.”
3.2 Loan aid, Grant 1. Confirm implementation of environmental review and information 1. Environmental review procedures in accordance with environmental categorization Necessity of conducting
Aid (excluding disclosure in accordance with categorization. ・ It was confirmed that the environmental checklists were prepared in 39 projects out of 42 of Category B projects. (For the projects environmental review at
projects executed - Preparation of the environmental checklist that the environmental checklists were not developed, other documents were used to check.) As for Category A projects, it was the time of E/S loan
through international - Approval and disclosure of EIA, ECC, RAP and IPP and confirmed that the EIA and/or RAP reports covered all the elements to be checked in the checklist. As for 7 Category FI projects, provision
organizations) and disclosure the institutional capacity of environmental and social management of the financial Intermediaries were reviewed, and no
Technical - In case cooperation projects fall under category FI, confirmation subprojects equivalent to Category A were planned (Nos.43, 56, 57, 59, 60, 81). In one FI project, JICA and FI agreed that
Cooperation Projects records of FI’s capacity on environmental and social environmental review and information disclosure consistent to the requirements of Category A will be carried out prior to its
considerations, and records of environmental review for category implementation if Category A-level subproject is planned (Project No.58). Refer to “2.1 Information Disclosure” for disclosure
“A “sub-projects (if any) status of EIA, ECC, RAP and IPP.
2. In case of E/S loan projects, summarize the records of
environmental review. 2. Environmental review in E/S loan projects
3. In case of E/S loan projects, confirm status of environmental and ・ Among the 100 projects, there were 4 E/S loan projects (Nos.13, 23, 34, 55). In all these projects, environmental review was
social considerations by project proponents etc. during the E/S skipped as per the JICA GL at the time of appraisal of E/S loan, because necessary environmental and social assessments are to be
stage carried out as part of activities covered by the E/S loan.
4. Confirm status of receipt and disclosure of monitoring results.
5. Confirm correspondence to a request on disclosure of monitoring 3. Status of environmental and social considerations during implementation by project proponents etc. in E/S Loan projects
results from the third party. ・ All four projects of E/S loan (Nos.13, 23, 34, 55) included environmental and social considerations activities (such as support on
6. Confirm if there was any differences between environmental preparation or review of EIA, RAP, etc., or support on implementation of monitoring activities). It is planned to conduct the

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Items of Current Including Recommendations from WG on Review of Operation Background and Reasons for Discussion Points (Draft)
JICA GL
review results and monitoring results and its reason (e.g. a need for following activities: support on environmental and social impact monitoring (No.13), review of draft EIA report and supplemental
more detailed descriptions in the GL, an interpretation problem of survey in line with the JICA GL (no land acquisition is included) (No.23), support on preparation of EIA and RAP (land
the GL, a capability/manpower/resource problem, etc.). acquisition and construction have not been started) (No.34), and support on preparation of EIA etc. (No.55).
7. Any project which JICA requested project proponents etc. to take
appropriate actions in accordance with agreement documents and 4.Submission and Disclosure status of monitoring result
suspend loan disbursement (if any). ・ In 45 projects, disclosure of environmental monitoring result was agreed between JICA and project proponents etc. Among them,
8. Confirm whether the JICA’s procedure for the project with construction activities were commenced in 29 projects at the time of review survey. All environmental monitoring results were
significant changes was applied. disclosed on the JICA website except for one project (No. 38) which was suspended due to deterioration of the security situation.
・ In 16 projects, disclosure of social monitoring result was agreed between JICA and project proponents etc. Among them, land
acquisition and involuntary resettlement have started in 10 projects. All social monitoring results were disclosed on the JICA
website except for one project (No. 38) which was suspended due to deterioration of the security situation.

5. Request from the third party to disclose monitoring results


・ In one project, local people requested disclosure of monitoring process and the results, and the relevant data was provided
accordingly. (No.33)

6. Differences between environmental review results and monitoring results


・ The results of environmental review and monitoring were reviewed to see if there are any differences (monitoring results were
checked against the monitoring plan proposed in EIA/RAP that were confirmed at the time of appraisal). Differences were
observed in five projects (Nos.5, 6, 11, 24, 42). These differences did not arise from the JICA GL text itself or differences in
interpretation but due to unforeseen events that were not anticipated in the EIA stage, or due to constraints in the operational
ability of the project proponents and relevant organizations. It was confirmed that the project proponents identified these
unanticipated impacts and dealt with them in all the projects.

7. Projects which JICA requested project proponents etc. to take appropriate actions in accordance with the agreement and
subsequently suspended disbursement
・ No such case was identified .

8. Procedures taken to Significant changes


・ Changes of project scope which were defined as “Significant change” by the JICA GL were identified in two projects. As for
Project No.04, the Zone B (Phase 2) project following Phase 1 is considered as a “significant change” because of the expansion of
the area targeted for investment. As for Project No.09, design change of access road component was considered as “significant
change”.
Recommendation from the 11th WG meeting for reexamination of JICA
GL Operation
【Additional Survey Items】E/S loan projects
【E/S loan projects】
・ Under the current GL, the timing of environmental appraisal/review has two options; prior to the provision of E/S loan or at the
9. If the project falls under para 2 of Section 3.2.1. (5) “Engineering provision of loan to the targeted project. However, some NGOs pointed out that environmental and social impacts have occurred
Service Loan” in the GL, instead of consulting with the Advisory
during the period of the E/S loan while environmental review was not concluded prior to E/S loan.
Committee for the first time at the environmental review stage,
there should be an opportunity to discuss at the Advisory
9. Recommendation from WG on Review of Operation
Committee meeting from the earlier stage, namely the scoping
・ The timing of the environmental review of the E/S loan and ODA loan to the project itself will be addressed as the discussion
stage of environmental and social considerations which are
point “Necessity of conducting the environmental review at the time of provision of the E/S loan”.
conducted by the project proponent in the E/S loan project.
3.3 Preliminary 1. Whether JICA recommended MOFA to suspend the cooperation 1. Cases that JICA recommended the MOFA of Japan to suspend the cooperation project.
Studies of Grant Aid project. ・ There is no project in which JICA recommended suspension of cooperation project to MOFA.
Undertaken by the
Ministry of Foreign
Affairs (MOFA) of
Japan
3.4 Technical 1. Confirm implementation of environmental and social 1. Environmental and social considerations procedures at each stage in accordance with categorization
Cooperation for considerations procedures at each stage in accordance with ・ Among the eight Technical Cooperation for Development Planning projects, environmental and social considerations procedures
Development categorization at each stage were implemented in accordance with the JICA GL. The following describes how the procedures at each stage as per
Planning 2. Screening the JICA GL were implemented with 7 projects with the exception of one Category C.
3. Scoping
4. Consultations 2. Implementation status of screening
5. Disclosure of agreement and/or safeguard documentation ・ It was confirmed that screening was implemented in all 7 projects.
6. Confirm implementation record of stakeholder meetings during

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JICA GL
SEA stage. 3. Implementation status of scoping
7. Experience which unexpected environmental and social impacts ・ Scoping including preliminary-scoping or draft scoping was conducted in all 7 projects.
were caused after completion of Technical Cooperation for
Development Planning, and its correspondence 4. Implementation status of consultation between JICA and project proponents etc.
・ Among the seven targeted projects, it was confirmed that consultation between JICA and project proponents etc. regarding follow
of the JICA GL were implemented in all seven projects.

5. Disclosure of agreement documents and/or reports


・ Reports of the detailed planning survey and agreement documents were disclosed on JICA’s website for all seven projects.

6. Stakeholder meetings during SEA stage


・ Implementation of SHMs at the SEA stage were confirmed in all 7 projects.

7. Experience which unexpected environmental and social impacts were caused after completion of Technical Cooperation for
Development Planning, and its correspondence.
・ In one project (No. 44), it was confirmed that some complaint letters were from farmers (including organization) whose lands
were affected were reached, the JICA office conveyed contents of appeals to the project proponent and requested them to
correspond to issues after conducting interviews accordingly.
Recommendation from the 5th WG for reexamination of JICA GL
Operation 8. Records of stakeholder meetings during SEA stage are shown in item 6. above and Section 1.2.3 (8) in Chapter 2.
【SEA】 ・ Implementation of SHMs at the SEA stage were confirmed in all 7 projects. In Project No.39, the Project for the Study on
8. It is necessary to consider how to conduct the stakeholder meeting Strengthening Competitiveness and Development of Sihanoukville Port, three times of stakeholder meetings were implemented in
at the SEA stage. three different venues in which 157 people attended in total, while in the Project No.40, the Project for Study on Integrated
9. It should be noted that EIA will be implemented at the project level Development of the Adjacent Zones to Yacyreta Dam Reservoir, two times of the stakeholder meetings were implemented in eight
in consideration of the contents of the study, consultation records different venues in which 327 people attended in total.
and information at the SEA stage. (i.e. utilization of previous
evaluation results, “Tiering”) 9. Tiering
・ In Japan's “Basic Matters”, it is required that a tearing that the contents considered to avoid or mitigate the impacts at alternative
analysis at the SEA stage will be sorted out at the EIA stage.
Section 4, 1 (5): “In cases where multiple plans concerning location etc. were compared, the details of the process of
decision-making on the location etc. relating to the target project from multiple plans shall be compiled so as to clarify how
environmental impact is avoided or reduced in the course of such decision-making.”
・ The approaches done by the WB and the IFC could not be confirmed.
Appendix Survey Items Survey Results Discussion Point
Including Recommendations from WG on Review of Operation Background and Reasons for Discussion Points (Draft)
Appendix 1. 1. Confirm methodology for quantifying cost and benefit related to 1. Methods of quantifying cost and benefit related to environmental and social considerations Target of quantification
Environmental and environmental and social considerations in Japan and other donors. 1.1 Calculation of cost of costs and benefits
Social ・ In the reviewed projects, the cost for land acquisition and implementation of environmental management plan and monitoring plan related to
Considerations were included in the calculation of the project cost. environmental and
Required for social considerations
Intended Projects 1.2 Inclusion of GHG emissions into the project cost and benefit analysis and its methods
・ Market price for GHG emissions already exists. Therefore, economic analysis of JICA projects, including reviewed projects, takes
into account an increase in GHG emissions as project costs and a decrease in GHG emissions as project benefits to calculate
EIRR. In particular, projects with large GHG emissions such as large-scale power generation projects include GHG emissions into
cost benefit analysis.
・ The Navoi Thermal Power Station Modernization Project in Uzbekistan (Project No.1) was to install a high-efficiency CCPP by
replacing existing power generation equipment in the aging thermal power plant. In this project, reduction of GHG emissions was
considered as project benefits and the economic value was assessed by using the average spot price of certified emissions
reductions of Blue Next (at that time).
・ The Shahid Rajaee Power Plant Construction Project in Iran was a new power plant construction project in which GHG emissions
were added into the project costs by using the trading price of the European Emission Trading Scheme.

1.3 Approach of Japan, WB, ADB and IFC


・ “The Basic Matters” in Japan does not require a quantitative cost benefit analysis.
・ In the WB ESS 1, it is described that the environmental and social impacts for each of the alternatives will be quantified to the
extent possible, with attachment of economic values where feasible. (ESS 1 Annex1-D) In addition, among environmental and
social costs and benefits that can be quantified will be included in economic analysis. (Guidelines for Economic Analysis of

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Power Sector Projects, 2015). Increase or reduction of GHG emissions will be added into the project costs or benefits respectively.
In this calculation, it is recommended to utilize the shadow price in reference to Shadow price of carbon in economic analysis
Guidance Note (2017).
・ In ADB’s SPS, it is stipulated that the borrower/client will examine alternatives to the project’s location, design, technology, and
components, taking environmental costs and benefits of the various alternatives considered into account while quantitative
analysis is not described. (SPS, Safeguard Requirements 1: environment) On the other hand, in economic analysis, increase or
reduction of GHG emissions will be added into the project costs or benefits respectively. The economic value of GHG emissions
use the same price for all projects with reference to the IPCC report. (Guidelines for the Economic Analysis of Projects, ADB,
para160, 161)
Recommendation from the working group meeting for reexamination of ・ In IFC’s Guidance Note, it is stipulated that the client should consider economic, financial, environmental and social costs and
JICA GL Operation benefits, but quantitative analysis is not described. (PS-1, Guidance Note 1, para 61)
【Environmental and social costs and benefits in project evaluation】
2. Generally, it is said that quantification of environmental and social 2. As described in item 1. above, cost for land acquisition, implementation of environmental management plan and monitoring plan
costs and benefits has challenges in the scope and methodology. were calculated and included in the project cost in the reviewed projects. In addition, an increase or reduction of GHG emissions
However, it is important to have a common understanding in the were added into the project costs or benefits respectively in economic analysis for calculating EIRR, because GHG emissions
Advisory Committee on how much and how this quantification amount can be converted into the market price. In particular, projects with high GHG emissions such as large-scale power
needs to be handled in JICA's cooperation projects. generation projects use GHG emissions in its cost benefit analysis.
3. On the other hand, it is desirable to consider the following points
when examining the specific approach in the future, taking into 3. The examples of JICA and approaches of the WB, ADB and IFC are as described in item 1. above.
consideration the JICA GL which says “to endeavor to include an
analysis of environmental and social costs and benefits in the most
quantitative terms possible”:
 For the environmental and social costs and benefits, it is also
necessary to consider the quantification of costs, while
quantification of benefits was discussed in the past.
 Additionally, it is important to consider the necessity of
“quantitative evaluation” and “economic evaluation” related
to environment and society.
 It is good to note that “internalization of various
environmental and social costs associated with development
into development costs” is not limited to the quantification of
environmental and social costs and benefits at the study phase,
and it could be broadly applied to the operation stage by
including mitigation measures in the EMP.
 It is desirable to refer to other aid agencies’ practices (e.g. by
reviewing the WB’s appraisal documents and other
documents)
 With regard to quantification of environmental and social
costs and benefits, it is necessary to discuss specifically by
accumulating actual practices in the projects.

4. Confirm methodology for environmental impact assessment of 4. Environmental impact assessment of disasters WB ESS 4
disasters in Japan and other donors. ・ There were three cases of environmental assessment impact studies in Japan conducted as per the Environmental Impact Addition to
Assessment Act in which assessment items were selected on the assumption of occurrence of disasters such as landslides and consideration items:
slope failures in the items of “Topography and Geology” and “Topography, Surface geology, Soil, Peculiar Natural Phenomenon”. Ensuring community
All three cases are development projects targeting relatively large chunk of land areas, and the assessment items were selected safety that may be
considering the potential risk of disasters such as landslide and slope failure that might occur due to large-scale of land affected by the project
reclamation (which potentially undermine the stability of slope and land surface).
・ It is stipulated in the WB ESS 4 “Community Health and Safety” that the Borrower will design, construct, operate, and WB ESS 4
decommission the structural elements of the project in accordance with national legal requirement, the EHSG and so on, taking Considerations relating
into consideration safety risks to third parties and affected communities. (para 6) Design of the structural element will be to climate change in the
incorporated to reflect climate change considerations. EHSG and GIIP will be referred for measures to address the impacts of design of infrastructure
Recommendation from the working group meeting for reexamination of climate change such as flooding. (ESS 4 GN 6.4) In addition, the Borrower will consider the incremental risks of the public’s
JICA GL Operation potential exposure to operational accidents or natural hazards, including extreme weather events during operation.
【Impacts of a disaster on the project and responses to accidents at the
operation stage】 5. How disasters are covered in impact assessments in Japan and WB projects are discussed in item 4 above. In addition, the
5. JICA has proposed, “since disasters such as earthquakes are reviewed projects are classified under the criteria for the relationship between projects and disasters which were discussed as Item

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JICA GL
different from environmental and social impacts caused by the 5 of the working group recommendation as follows:
project, it is considered that disasters are not subject to the EIA.”  In case the project which lowers the resilience of the project site and increases disaster risks.
However, it is not desirable to exclude disasters from the scope of Two projects were confirmed among the reviewed projects. In Project No. 14 Mandimba-Lichinga Road Upgrading Project in
“environmental impact assessment” because the following cases Mozambique, the risks of soil runoff were pointed out caused by filing and cutting of soils in the mountainous areas, and
may be considered: countermeasures against soil runoff is planned in the ESMP to be taken as needed. In addition, in Project No.35, Project for
 Cases that the project lowers the resilience of the project site Olkaria Geothermal Power Development in Republic of Kenya, since landslide etc. may occur by filling and cutting of soils in
and increases disaster risks; places where the ground is weak, mitigation measures such as installation of retaining walls, barricades and signs that indicate
 Cases that the project may directly trigger disasters (e.g. danger were included in the ESMP as necessary.
construction of a dam might induce earthquakes); and  In case there is a concern that the project may directly trigger disasters. (e.g. Construction of a dam might induce earthquakes.)
 Cases that the project may directly trigger disasters (e.g. Not identified.
construction of a power plant might contribute to global  In case there is a concern that the project may directly trigger disasters. (e.g. Construction of a power plant might contribute to
warming). global warming.)
6. If the cases above are subject to EIA, it should be discussed either Not identified.
of the following two ways is appropriate: to add “disaster” as an
item of environmental and social considerations, or to evaluate for 6. Disasters such as landslides and slope failures were conventionally addressed using existing check items (Geographical features,
disasters in the environmental existing checklists of the JICA GL etc.).
(i.e. geography, geology, etc.), which needs to be discussed.
7. If the cases above are subject to EIA, the responsible agency of 7. In general, similar to the accident prevention, consultants/contractors who are in charge of design (and project proponent) at the
disaster prevention such as earthquakes should be clarified at the detailed design stage, construction contractors (and project proponent) at the construction stage, and project proponent at the
construction and operation stages in addition to the detailed design operation stage are responsible to formulate and execute disaster prevention measures such as earthquakes.
stage (same as the responsible agency for accident prevention).
8. It is desirable to define and differentiate the concept of disasters 8. In the Basic Act on Disaster Management in Japan, it is stipulated in Article 2 (1) that the term “disaster“ is defined as damages
and accidents. resulting from a storm, tornado, heavy rainfall, heavy snowfall, flood, slope failure, mudflow, high tide, earthquake, tsunami,
eruption, landslide, or other abnormal natural phenomena, or a large fire or explosion or other causes provided for by Cabinet
Order and similar to the above in the extent of damage they cause. There is no clear definition of the term “accident” in the
Environmental Impact Assessment Act, but in general the accidents are caused by human factors. In WB ESF and ESS, IFC PS,
requirements on impact assessments and the countermeasures for disasters and accidents are not clearly described separately. For
example, an emergency event which the Borrower will identify and implement measures to address is an unanticipated incident,
arising from both natural and man-made hazards, typically in the form of fire, explosions, leaks or spills, which may occur for a
variety of different reasons, including failure to implement operating procedures that are designed to prevent their occurrence,
extreme weather or lack of early warning. (ESS 4 para 19)
Underlying 1. Confirm status of investigation and examination on environmental 1. Investigation and examination of environmental and social impacts at the planning stage.
Principles and social impacts at the planning stage. ・ Investigation and examination status on environmental and social impacts at the planning stage was confirmed for 90 projects
2. Confirm status of examination on alternatives and mitigation (excluding 10 Category C projects). Subsequent analysis is based on the review of 90 projects.
measures to avoid and minimize environmental and social impacts.
3. Confirm if the above-mentioned examination results were reflected 2. Alternative analysis and preparation of mitigation measures to avoid and minimize environmental and social impacts.
in the project plan. ・ It was confirmed that alternative analysis was conducted and/or mitigation measures were planned in all 41 Category A projects
4. Confirm if costs and benefits related to environmental and social and all 42 Category B projects. Seven FI projects are not applicable to this requirement.
considerations were tried to be evaluated quantitatively and
evaluated qualitatively. 3. Confirmation on how these analysis was reflected to the project design
5. Confirm if costs and benefits related to environmental and social ・ It was confirmed that in all 79 projects in which alternative analysis was conducted, the option with relatively small environmental
considerations were closely harmonized with economic, financial, and social impacts was selected as a result of alternative analysis.
institutional, social and technical analyses of the project.
6. Confirm if results of environmental and social considerations study 4.Confirmation on whether efforts were made to quantify environmental and social costs and benefits and whether the quantitative
including examination on alternatives and mitigation measures analysis is complemented by qualitative assessment
were specified in a separate document or part of other documents. ・ As for the project costs, quantitative analysis was conducted to evaluate the cost of land acquisition, implementation of
7. Confirm if an environmental impact assessment report was environmental management and monitoring plan. In some cases, increase or reduction of GHG emissions were added into the
prepared for projects especially with significant environmental and project costs or benefits respectively in economic analysis for calculating EIRR. In addition, qualitative evaluation was undertaken
social impacts. on positive and negative impacts of the project and to assess impacts associated with external factors.
8. Confirm if experts committee was established for projects with
especially significant environmental and social impacts and 5.Cost and benefit analysis related to environmental and social considerations were closely harmonized with economic, financial,
arguable projects. institutional, social and technical analyses of the project
・ It was confirmed environmental and social costs and benefits were included in the calculation of EIRR in 44 out of the 90
projects. On the other hand, there were 46 projects for which calculation of EIRR was not required (19 projects of ODA Grants
excluding Category C Projects, 7 projects of FI, 7 projects of Technical Cooperation for Development Planning, 3 projects of
Technical Cooperation, 3 projects of E/S, and 6 projects of Small and Medium-sized Enterprise support projects).

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6.Confirmation on whether results of environmental and social considerations study including examination on alternative and
mitigation measures were specified in stand-alone document or part of other documents
・ In all 83 projects in which alternative analysis was implemented and/or mitigation measures were prepared, the results were
described in a part of other documents.

7. Confirmation on whether EIA report was prepared for projects with significant environmental and social impacts
・ It was confirmed that EIA or ESIA was prepared in all Category A projects except Technical Cooperation Projects.

8.Confirmation on whether experts committee was established for projects with significant environmental and social impacts and
controversial projects
・ There were no cases that a committee was established by inviting experts due to the magnitude of impacts and/or controversy of
the project (except committees for land acquisition and environmental management, or committees to be set up as per normal
administrative procedures in the host country).

【Additional survey items】Requirements related to FI added to the WB ESF Necessity of


・ WB ESS 9 “Financial Intermediaries” applies to FIs that receive financial support from the Bank. (ESS 9 para 4) application of the
requirements according
・ Where FI subprojects are likely to have minimal or no adverse environmental or social risks or impacts, the FI will apply national
to the risks to financial
law. On the other hand, the WB ESSs will be applied to subprojects that pose significant risks. (ESS 9 para 11)
intermediaries and
・ The procedures for the environmental and social consideration confirmation of the subproject conducted by FI itself is established
reference to
as ESMS. The contents of ESMS mainly include environmental and social policy, clearly defined procedures for the
establishment of ESMS
environmental and social considerations confirmation (categorization, environmental impacts, monitoring, etc.), implementation
as required in WB ESS
of monitoring of subprojects and submission of annual report of each subproject. (ESS 9 para 14-23)
9
・ Under the IFC’s Interpretation Note on FI, IFC requires its FI clients to develop and operate an ESMS in instances where the
activities that are supported by IFC financing present E&S risks. The scope and complexity of the ESMS should be commensurate
with the level of E&S risk associated with the asset class supported, and the ESMS should incorporate relevant principles of PS 1.
FI subprojects with higher E&S risks are required to apply the PSs. Clients for subprojects that have adverse risks will be required
to implement a simple E&S screening procedure. (IN 13, footnote IN 13)
Examination of 1. Confirm if appropriate plan and structure for follow-ups, such as 1. Preparation status of Environmental Management Plan (EMP) and Environmental Monitoring Plan (EMoP)
Measures environmental management plan and monitoring plan are prepared, In many cases, the Environmental Management Plan (EMP) was attached to the contractor's bidding documents, and the costs of the
and its cost and procurement method are examined. EMP and the Environmental Monitoring Plan (EMoP) were often allocated as part of the management cost of the project proponent and
2. (Other items will be confirmed through the review of Section 2.8.) the contract amount of the contractor.
Scope of Impacts to 1. Confirm if appropriate scoping was fully conducted as per the GL. 1. Appropriate Scoping ESS 3 Necessity of
Be Assessed 2. Confirm if the amount of GHG emission by the project was ・ Out of 90 projects (100 projects minus 10 Category C projects), it was confirmed that scoping was conducted in 82 projects. (7 FI reference to
calculated and evaluated. projects are not applicable for this requirement) requirements in WB
3. Confirm practices of multilateral and bilateral donors on climate ESS3: hazardous
change (GHG emission) and pollution control 2. Implementation status of calculation/evaluation of GHG emissions wastes, chemical
・ Out of 90 projects (100 projects minus 10 Category C projects), it was confirmed that GHG emissions were calculated and/or hazardous materials,
evaluated in 20 projects. Sectors of the projects in which GHG emissions were calculated include power generation, railways, and pest management
roads, and airports.

3. Climate change and pollution control


3.1. ESS 3: Resource Efficiency and Pollution Prevention and Management
・ The Borrower will avoid the release of pollutants or, when avoidance is not feasible, mitigate their release using the performance
levels and measures specified in national law or the EHSGs, whichever is most stringent.
・ The Borrower will avoid the generation of hazardous and nonhazardous waste. Where waste generation cannot be avoided, the
Borrower will minimize the generation of waste, and reuse, recycle and recover waste. Where waste cannot be reused, recycled or
recovered, the Borrower will treat, destroy, or dispose of it in an environmentally sound and safe manner (ESS 3 para 17-18)
・ The Borrower will avoid the manufacture, trade and use of chemicals and hazardous materials subject to international bans,
restrictions or phaseouts unless for an acceptable purpose as defined by the conventions or protocols. The production,
transportation, handling, storage, and use of hazardous materials for project activities will be assessed through the environmental
and social assessment. (ESS 3 para 19-20)
・ Where projects involve recourse to pest management measures, the Borrower will give preference to integrated pest management
(IPM) or integrated vector management (IVM) approaches. The Borrower will not use any pesticides or pesticide products or
formulations unless such use is in compliance with the EHSGs, or that are restricted under applicable international conventions or
their protocols. In addition, the Borrower will also not use any formulated pesticide products that meet the criteria described in
ESS3 para 22, 23. For any project involving significant pest management issues or any project contemplating activities that may
lead to significant pest and pesticide management issues, the Borrower will prepare a Pest Management Plan (PMP). (ESS 3 para

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21-25)
・ Also, in IFC's PS3 “Resource Efficiency and Pollution Prevention”, if there is a difference between the domestic law of the
country where the project is implemented and the requirements and measures in the EHS guidelines, the IFC business will be
required to meet the stricter requirements.

3.2. Predictive quantification of GHG emissions stipulated in MDBs’ safeguard policies.


WB IFC ADB Estimation of
Scope of predictive The Borrower will estimate gross GHG For projects that are expected For projects that that produce greenhouse gas (GHG)
quantification of emissions resulting from the project, to or currently produce more more than 100,000 tons of CO2 emissions from project
GHG emissions except the following projects. (ESS 3, than 25,000 tons of CO2 equivalent per year for the
para 16) Scope 1 is only targeted to equivalent annually (PS 3, para aggregate emissions of Scope
avoid double counting (GN 16.1) 8). 1 and Scope 2. Quantify
- Projects that have diverse and small Quantify Scope 1 annual Scope 1 and Scope 2 annual
sources of emissions (for example, emissions and Scope 2 annual emissions (SPS Appendix 1,
community-driven development emissions. (GN 3, Annex A) footnote 10)
projects); and
- Projects where emissions are not
likely to be large amount (for example,
projects for education and social
protection)
Calculation threshold No specific reference/ requirements More than 25,000 tons of The total emission amount of
carbon dioxide equivalent per scope 1 and scope 2 is 100,000
year (PS 3, para 8) tons of carbon dioxide
equivalent or more per year
(SPS Appendix 1, footnote 10)
Frequency of As part of environmental and social Quantification once a year (PS Quantification once a year
emissions calculation impact assessment, emissions are 3, para 8) (SPS, para 39)
estimated once before the project
implementation (ESS3, para 16)
Method of Method of information disclosure will Clients are encouraged to Method of information
information be published through ESIA according disclose their GHG emissions disclosure will be published
disclosure to risk classification of the project annually through corporate through ESIA
reports, or through other
voluntary disclosure
mechanisms currently being
used by private sector
companies internationally.
(GN3, para19)
・ In ESS 3, GHGs includes CO2, methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs),
Sulphur hexafluoride (SF6), and nitrogen trifluoride (NF3).
・ Under the EP 3, quantification of GHG emissions will be conducted by the client in accordance with internationally recognized
methodologies and good practice, for example, the GHG Protocol. The client will quantify Scope 1 and Scope 2 emissions.
・ In the current JICA GL, although the scope of impact to be assessed includes climate change, there is no provision for calculation
of GHG emissions or its reporting. Meanwhile, JICA has adopted the Climate Finance Impact Tool for Mitigation (JICA Climate
FIT (Mitigation)) as a tool to estimate GHG emission reduction against the baseline scenario.

3.3. Alternative analysis for technically and financially feasible and cost-effective GHG emission reductions stipulated in MDBs’
safeguard policies
WB IFC ADB Alternative analysis for
The Borrower will consider alternatives and The client will consider alternatives and No description cost-effective GHG
implement technically and financially feasible implement technically and financially emission reductions
and cost-effective options to avoid or feasible and cost-effective options to reduce with technical and
minimize project-related air emissions during project-related GHG emissions during the financial feasibility
the design, construction and operation of the design and operation of the project. (PS 3,
project. (ESS 3, para 15) para 7)

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・ EP 3 requires an alternatives analysis to reduce GHG emissions to be conducted by the client when the Project is expected to emit
more than 100,000 tons of CO2 equivalent annually. (EP 3, June 2013, Annex A)

3.4. Contribution to the target of the Paris Agreement (below 2 degrees Celsius above pre-industrial levels)
Recommendation from the working group meeting for reexamination of ・ Donors that stipulated contribution to the target of the Paris Agreement in the SGP were not identified.
JICA GL Operation
【Climate change】 4. With regard to climate change:
4. Although there are some challenges on climate change which are  JICA's overall strategy and plan to address climate change will be considered in the future, taking into consideration the
beyond the scope of reexamination of JICA GL operations, the policies of the Japanese government, etc.
following points can be considered as the issues to be discussed in  For the calculation and evaluation of GHG emissions, see the item 3. Climate Change and the “Estimation of GHG emissions
the future. from the projects” of the Point of Argument.
 The overall carbon management strategy of JICA needs to be 5. Currently, based on the recommendations at the time of review of operation, “climate change (GHG emissions)” is used.
clarified at the earliest.
 Not only for projects in which is expected to reduce GHG 6. The WB, ADB, and IFC stipulate that total GHG emissions in the life cycle of a project will be predicted in environmental and
emissions, but also for projects in which would not reduce social impact assessment prior to the start of the project. In addition, IFC and ADB stipulate that the quantification will be
GHG emissions, GHG emissions should be calculated to conducted annually.
grasp total GHG emissions from entire JICA projects.
 The impacts of climate change should be evaluated by 7. The WB stipulates that direct emissions (Scope 1) will be quantified, while IFC and ADB stipulate that direct emissions (Scope 1)
measurement of emissions, not by emission reduction. and indirect emissions from energy use (Scope 2) will be quantified. As of 2019, no MDBs were identified that require estimation
5. As environmental items for scoping, “climate change (GHG of other indirect emissions (Scope 3).
emission)” is suitable rather than “global warming.”
6. In order to grasp the GHG emissions from the entire JICA projects,
it is suggested that in principle, GHG emissions during the
construction phase should be also evaluated, except only the case
where the GHG emissions are particularly negligible compared to
the operation phase.
7. It is desired that the assessment of GHG emissions for the supply
chain is also taken into consideration in the future. For example, as
for large-scale development projects of the road or railway sector,
it is assumed that a large amount of CO2 is generated at the time of
production of cement. Therefore, it is necessary to consider
whether (1) evaluation of GHG emissions associated with
production of the raw materials and (2) management and recording
of cement consumption could be required.

Recommendation from the 5th working group meeting for


reexamination of JICA GL Operation 8. As described in the item 2, among the 90 projects, quantitative evaluation of GHG emissions were implemented in 20 projects.
【Climate change】
8. As for climate change (GHG emissions) at the scoping stage, a
baseline is set in accordance with a certain methodology such as
JICA's Climate Finance Impact Tool for Mitigation (JICA Climate
FIT (Mitigation)), and the mitigation effect is evaluated by
comparing with that baseline. However, just like other impact
items, it might be possible to evaluate the impact of climate change
(GHG emissions), compared with the current status as a reference
point.
9. Summarize practices on examination and assessment of derivative, 9.Case study of indivisible projects, derivative and secondary impacts, and cumulative impacts WB ESS 1
secondary, and cumulative impacts as well as the impacts of ・ Indivisible projects: Out of 90 projects (90 projects excluding 10 Category C projects), four projects were identified as indivisible Necessity of reference
indivisible projects projects. They are: switch yard project of power generation project (No.19), improvement of sewage treatment plant where to definitions of
existing sludge treatment site was also subject to EIA (No.22), a section of a road financed by co-financier in the co-financing “associated facility”,
road project (No.28) and borehole project of geothermal project that is conducted by the host country (No.35). “derivative impacts,
・ Derivative and secondary impacts: Two projects (Nos.21, 41) were identified. As for Project No.21, since it was predicted that secondary impacts”,
shops and houses around roads would increase, the issue was raised to promote measures for waste reduction and proper and “cumulative
treatment, and countermeasures for water pollution caused by domestic wastewater etc. As for Project No.41, positive impacts impacts”
such as maintenance and management of roads and provision of social services to residents due to the presence of power plant
facilities etc. were identified, and no mitigation measures were implemented because only positive impacts were expected.

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JICA GL
・ Cumulative impact: Two projects were identified. In the Project No.19 of power generation project, cumulative impacts on air and
water quality caused by existing power plants were identified, while in the Project No.35 of the phase 5 of the geothermal power
plant project, cumulative impacts caused by future development in consideration of the past impacts on biodiversity conservation,
air, water quality, noise, soil, waste, etc. in the specific area were identified.

10. Summarize practice of WB, ADB and IFC on examination and 10. Approaches of WB, ADB and IFC to indivisible projects, derivative and secondary impacts, and cumulative impacts
assessment of derivative, secondary, and cumulative impacts as
10.1. Approaches of WB, MDBs etc. to indivisible projects
well as the impacts of indivisible projects.
・ WB: Associated Facilities are facilities that are not funded as part of the project and, in the judgement of the Bank are: (a) directly
and significantly related to the project; and (b) carried out, or planned to be carried out, contemporaneously with the project; and
(c) necessary for the project to be viable and would not were constructed or expanded or conducted if the project did not exist.
(ESS 1, para11) Associated Facilities will meet the requirements of the ESSs, to the extent that the Borrower has control or
influence over such Associated Facilities. (ESS 1, para 10)
・ ADB: Associated facilities are not funded as part of the project (funding may be provided separately by the borrower/client or by
third parties), and whose viability and existence depend exclusively on the project and whose goods or services are essential for
successful operation of the project (SPS, Appendix 1, para 6)
・ IFC: Associated facilities are facilities that are not funded as part of the project and that would not have been constructed or
expanded if the project did not exist and without which the project would not be viable. (PS1, para 8)
・ According to the FAQ of JICA’s GL, referring to the definition by IFC, JICA defines “indivisible projects” as related projects for
which JICA does not cooperate, 1) which involve associated facilities that would not were constructed or expanded if the project
Recommendation from the working group meeting for reexamination of for which JICA cooperates did not exist, and 2) without which, the project for which JICA cooperates would not be viable.
JICA GL Operation
【Indivisible projects】 11. As for the specific examples, four projects were identified among the projects targeted for review as described in item 9 above.
11. Regarding the scope of “the extent that is reasonably predictable”,
it is necessary to clarify it by accumulating precedents. 12. Based on the recommendations from the working group meeting for reexamination of JICA GL Operation, it was added in FAQ
12. In dealing with the indivisible projects, it should be clearly stated that “JICA checks whether or not the documents on environmental and social considerations (Resettlement Plan, Environmental
that “appropriate environmental and social considerations Impact Assessment (EIA) reports, etc.) of indivisible projects were prepared in accordance with the JICA GL, to the extent that is
documents” of the indivisible projects means that JICA needs to reasonably predictable. Where necessary, JICA will request project proponents etc. to incorporate environmental and social
confirm whether environmental and social considerations considerations into the projects to the extent required by the JICA GL.
documents of the indivisible projects comply with the JICA GL.
13. Although “indivisible projects” is specified as one of the “Impacts 13. In para 10 of the WB ESS 1, it is stipulated that Associated Facilities will meet the requirements of the ESSs, to the extent that the
to be assessed” in the JICA GL, it seems somewhat difficult to Borrower has control or influence over such Associated Facilities. In addition, where necessary, JICA will request project
study and consider the impacts of the indivisible projects which is proponents etc., to incorporate environmental and social considerations into the projects as shown in item 12. above.
not financed by JICA.
14. In order to clarify the contents of “indivisible projects”, major 14. Based on the recommendations at the time of operation review, a case of the power transmission line is added to the FAQ as an
examples/precedents should be presented. example of indivisible projects. Four projects were identified among the projects targeted for review. (See 9 above)
15. Since it is necessary to mention that there are various “indivisible
projects,” these examples should be described in the FAQ of the 15. In reference to the results of the review survey, some case studies of indivisible projects are planned to be added in the FAQ in the
JICA GL in the future future.
10.2 Approaches of MDBs to derivative and secondary impacts
・ WB: An indirect impact is an impact which is caused by the project and is later in time or farther removed in distance than a direct
impact, but is still reasonably foreseeable, and will not include induced impacts. (ESS 1, footnote 21)
・ ADB: At an early stage of project preparation, the borrower/client will identify potential direct, indirect, cumulative and induced
environmental impacts on and risks to physical, biological, socioeconomic, and physical cultural resources and determine their
significance and scope, in consultation with stakeholders, including affected people and concerned NGOs. (SPS, Appendix 1, para
4)
・ IFC: Impacts from unplanned but predictable developments caused by the project that may occur later or at a different location; or
indirect project impacts on biodiversity or on ecosystem services upon which Affected Communities’ livelihoods are dependent
(PS1, para 8)
・ According to the FAQ of JICA’s GL, referring to the definition by IFC, JICA’s definition of “derivative and secondary impacts”
are impacts from unplanned but predictable developments caused by the project, for which JICA cooperates, that may occur later
or at a different location. On the other hand, in the WB ESS, it is described that indirect impact is “an impact which is caused by
the project and is later in time or farther removed in distance than a direct impact, but is still reasonably foreseeable”, and will not
include induced impacts.

【Derivative impacts, secondary impacts】 16. As for the specific examples, four projects were identified among the reviewed projects as described in item 9 above.

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16. Regarding the scope of “the extent that is reasonably predictable”,
it is necessary to clarify it by accumulating precedents. 17. In addition to IFC PS referenced during the review of operation in 2014, more comprehensible will be considered referring the
17. IFC PS defines them as “(ii) impacts from unplanned but definition of “indirect impact” under WB ESS 1.
predictable developments caused by the project that may occur
later or at a different location; or (iii) indirect project impacts on 18. The examples of derivative and secondary impacts are as described in item 9 above.
biodiversity or on ecosystem services upon which Affected
Communities’ livelihoods are dependent.”. As for (iii), only the 19. Among the Category A projects, the Advisory Committee pointed out derivative and secondary impacts in one project, National
impact on the ecosystem is discussed, giving an impression that the Road No.5 Improvement Project (Thlea Ma'am-Battambang and Sri Sophorn-Poipet Sections) (I). Since it was pointed out at the
impact on the social aspect is not considered. Therefore, (iii) DF/R stage, explanations were given at the general meeting of the DF/R stage and the Environmental Review stage.
should be deleted to avoid misunderstanding, if the social aspect is 20. In addition to IFC PS referenced during the review of operation in 2014, it will be considered referring the definition of “indirect
also considered in (ii). impact” under WB ESS 1.
18. In order to clarify the contents of “derivative and secondary
impacts”, major examples/precedents should be presented.
19. Whether the project has “derivative and secondary impacts” and its
contents should be explained to the advisory committee in the early
stage by utilizing the opportunity when the project summary is
explained at the general meeting of the advisory committee.
20. “Unplanned but predictable development” includes a wide range of
factors including expansion.

10.3 Approaches of MDBs etc. to cumulative impacts


・ WB: The cumulative impact of the project is the incremental impact of the project when added to impacts from other relevant
past, present and reasonably foreseeable developments as well as unplanned but predictable activities enabled by the project that
may occur later or at a different location. Cumulative impacts can result from individually minor but collectively significant
activities taking place over a period of time. The environmental and social assessment will consider cumulative impacts that are
recognized as important on the basis of scientific concerns and/ or reflect the concerns of project-affected parties. The potential
cumulative impacts will be determined as early as possible, ideally as part of project scoping (ESS 1, footnote 22)
・ ADB: The project’s area of influence includes (a) areas and communities potentially affected by cumulative impacts from further
planned development of the project, other sources of similar impacts in the geographical area, any existing project or condition,
and other project-related developments that are realistically defined at the time the assessment is undertaken; and (b) areas and
communities potentially affected by impacts from unplanned but predictable developments caused by the project that may occur
later or at a different location. (SPS, Appendix 1, para 6)
・ IFC: Cumulative impacts result from the incremental impact, on areas or resources used or directly impacted by the project, from
other existing, planned or reasonably defined developments at the time the risks and impacts identification process is conducted.
(PS1, para 8)
・ According to the FAQ of JICA’s GL, referring to the definition by IFC, JICA defines the “cumulative impacts” as cumulative
impacts resulting from the incremental impact, on areas or resources used or directly impacted by the project for which JICA
cooperates, from other planned or reasonably defined developments at the time the risks and impacts identification process is
【Cumulative impacts】 conducted (e.g. scoping).
21. Regarding the scope of “the extent that is reasonably predictable”,
it is necessary to clarify it by accumulating precedents. 21. As for the specific examples, four projects were identified among the projects targeted for review as described in item 9 above.
22. In order to make the contents of “cumulative impacts” clearer, the
major examples/precedents should be presented. 22. Based on the recommendation at the time of review of operation, it was added in the FAQ that “for instance, in a road project,
23. There are various international discussions on “cumulative JICA has requested a host country to consider incremental impacts of the possible accumulation of houses and commercial
impacts”, so there is no need to rush to define the definition and facilities along the roads to be developed”.
scope, but to reconsider them based on international trends.
24. Whether the project has “cumulative impacts” should be explained 23. Definition of “cumulative impacts” by MDBs are shown in item 10 above.
in the early stage by utilizing the opportunity when the project
summary is explained at the general meeting of the advisory 24. Among the Category A projects targeted for review, it was confirmed in the Olkalia V Geothermal Power Development Project in
committee. Kenya (Project No.35) that noise from multiple power plants was assumed as cumulative effects at the DF/R stage, therefore,
25. The “cumulative impact” should include impacts of “persons’ mitigation measures such as distribution of personal protective equipment to employees were planned. These were explained as
activities”. the environmental review policy at the general meeting of the advisory committee.

25. Under the Council on Environmental Quality’s regulations in the United States, cumulative impacts include 'persons’ activities'.
On the other hand, the WB, IFC, ADB's definitions of cumulative impacts do not include 'persons’ activities' in the definition of
the cumulative impacts.
【Additional survey items】Scope of items to be assessed expanded under the WB ESF WB ESS 2 Necessity of

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・ WB ESS 2 “Labor and Working Condition” reference to LMP and
・ Scope of application:It is applied to the following four categorized project workers; a) people employed or engaged directly measures relating to
by the Borrower (direct workers), b) people employed or engaged through third parties (contracted workers); c) people occupational health and
employed or engaged in providing community labor (community workers), d) people employed or engaged by the Borrower’ safety
s primary suppliers (primary supply workers). For a) and b), the LMP, the OHSM and grievance mechanism mentioned
below are required. For c), a part of the LMP and the OHSM are required depending on the nature and scale of the project.
For d), the measures mentioned below are not required, but improvement measures are required if serious defects in child
labor, forced labor and occupational safety are identified.
・ Development of LMP: It contains working hours, calculation method of salary, overtime work, clear employment conditions
including pension, etc., prohibition of discriminatory employment etc., prevention of exploitation, consideration for the
vulnerable people, freedom of association and collective bargaining, prohibition of child labor and forced labor.
・ Development of OHSM: It is a document that arranges the occupational health and safety measures based on the relevant
EHS guidelines. It is to be prepared by the project proponent, and implemented and controlled by the contractor.
・ Grievance mechanism: It is required to establish the grievance mechanism for labors .
・ In the IFC PS 2 “Labor and Working Conditions”, although there are no specific documents such as Labor Management
Procedures and Occupational Health and Safety Measures stipulated in the WB ESS, important elements of labor and occupational
health and safety stipulated in WB ESS 2 are almost equally covered.
・ In the JICA GL, “working conditions (including occupational safety)” was described in the “Scope of Impact to Be Assessed” in
Annex 1, but there is no rule other than that.
・ WB ESS 4 “Community Health and Safety”
・ Preparation of ERP: In a project where there may be an emergency (human and natural), risks to community health and WB ESS 4 Addition of
safety will be identified through ESIA. ERP will be prepared as needed through the risk analysis and assessment. emergency response,
・ ERP regarding dam: For dams including a water storage dam for a hydropower, water supply, irrigation, or flood control, etc., dam safety, hazardous
safety measures will be developed by the engineer with capacity in accordance with GIIP. waste, inflow of
・ Preparation of Hazardous Waste Management Plan: In a project where the affected communities are likely to be exposed to workers, risk of security
dangerous materials, dangerous materials will be identified, the implementation system and responsible body for storage, personnel, ensuring of
operation, usage and disposal will be clarified, and implementation of management monitoring plan and mitigation measures community safety that
will be considered. Definition of dangerous materials follows the EHSG. (*Hazardous waste management in the working may be affected by the
environment is required to be implemented as part of pollution control in ESS 3.) project to the
・ Impact of labor influx from outside region and its countermeasures: It was stated that the risks related to labor influx consideration items
(infectious diseases, etc.) is taken into consideration. According to the WB GN on Managing Risks Related to Labor Influx, under JICA GL
key principles are “reduction of labor influx,” “assessment and management of labor influx risk through ESIA, etc.” and
“incorporation of social and environmental mitigation measures into the civil works contract.” WB ESS 4
・ Security Personnel: The risk to the community inside and outside the project area caused by security measures will be Consideration of
assessed, and if there is a complaint about illegal or violent behavior, it will be reviewed. climate change into the
・ Securing the safety of infrastructure and structures: The design and construction of structures will be conducted in design of structure
consideration of the safety of surrounding communities and climate change. If the risk of abnormal weather (including
sudden and/or moderate weather changes associated with climate change) is high, independent experts will validate the
design of the structure.
・ There is no big gap between the IFC PS 4 “Community Health, Safety, and Security” and the WB ESS 4. However, the WB ESS 4
requires climate change to be considered in terms of structural safety.
・ WB ESS 8 “Cultural Heritage”
・ It applies to “tangible cultural heritage” and “intangible cultural heritage”. Tangible cultural heritage includes movable or WB ESS 8 Addition of
immovable objects, sites, structures, groups of structures, and natural features and landscapes that have archaeological, intangible cultural
paleontological, historical, architectural, religious, aesthetic, or other cultural significance. Intangible cultural heritage heritage to
includes practices, representations, expressions, knowledge, skills—as well as the instruments, objects, artifacts and cultural consideration items
under JICA GL
spaces associated therewith — that communities and groups recognize as part of their cultural heritage, as transmitted from
generation to generation and constantly recreated by them. (ESS 8 para 4)
・ The requirements of this ESS 8 will apply to all projects that are likely to have risks or impacts on these cultural heritages.
This will include a project which: (a) Involves excavations, demolition, movement of earth, flooding or other changes in the
physical environment; (b) Is located within a legally protected area or a legally defined buffer zone; (c) Is located in, or in the
vicinity of, a recognized cultural heritage site; or (d) Is specifically designed to support the conservation, management and
use of cultural heritage. As for intangible cultural heritage, it applies only if a physical component of a project will have a
material impact on such cultural heritage or if a project intends to use such cultural heritage for commercial purposes. (ESS
8, para 5,6)
・ Through the environmental and social assessment, the Borrower will determine the potential risks and impacts of the

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proposed activities of the project on cultural heritage. Where appropriate, the Borrower will develop a Cultural Heritage
Management Plan. (ESS 8 para 8, 9)
・ If unknown cultural heritage is encountered during project activities (such as construction), the cultural heritage will be dealt
in accordance with a chance finds procedure that is prepared in each project. (ESS 8 para 11)
・ Considerations regarding the IFC PS 8 “Cultural Heritage” are the same as the WB ESS 8.
Compliance with 1. Summarize cases that under “protected areas that are specifically 1. Cases that fall under “protected areas that are specifically designated for the conservation of nature or cultural heritage.” WB ESS 6 Reference to
Laws, Standards, and designated for the conservation of nature or cultural heritage.” ・ None of 90 projects was implemented in “protected areas that are specifically designated for the conservation of nature and definition of habitats
Plans 2. Summarize practice of WB, ADB and IFC on cases of which cultural heritage”. On the other hand, seven projects were identified where the projects are located near protected areas. (Nos. 5, and protected areas, and
project area was in “protected areas that are specifically designated 18, 21, 24, 35, 41, 42). its risk management
for the conservation of nature or cultural heritage.” approach
3. (Other items will be confirmed through the review of Section 2.6.) 2. Practices of WB, ADB and IFC on cases of which project area is in “protected areas that are specifically designated for the
conservation of nature or cultural heritage”
Necessity of change of
2.1. Assessment of risks and impacts the rule: from the rule
・ Under the WB ESS 6 “Biodiversity Conservation and Sustainable Management of Living Natural Resources”, the Borrower will that in principle project
identify the potential project-related risks to and impacts on habitats and the biodiversity that they support. The Borrower will shouldn’t be
manage potential risks and impacts by avoiding, minimizing, then mitigating them (application of the mitigation hierarchy). implemented in the
Where significant residual impacts remain after the Borrower implements the mitigation measures to avoid, minimize and mitigate protected area to the
the risks and impacts, the Borrower will compensate for or offset them. The Borrowers will adopt the precautionary approach and one that project can be
apply adaptive management practices in the implementation of mitigation measures. implemented based on
・ ADB stipulates that the borrower/client will assess the significance of project impacts and risks focusing on the major threats to the classification of the
biodiversity, which include destruction of habitat and introduction of invasive alien species, and on the use of natural resources in habitat area
an unsustainable manner. The borrower/client will need to identify measures to avoid, minimize, or mitigate potentially adverse
impacts and risks (application of the mitigation hierarchy). (SPS Appendix 1, para 24)
・ Under IFC PS 6 “Biodiversity Conservation and Sustainable Management of Living Natural Resources”, the client should assess
direct and indirect project-related impacts on biodiversity and ecosystem services and identify any significant residual impacts. As
a matter of priority, the client should seek to avoid impacts on biodiversity and ecosystem services. When avoidance of impacts is
not possible, measures to minimize impacts and restore biodiversity and ecosystem services should be implemented. Given the
complexity in predicting project impacts on biodiversity and ecosystem services over the long term, the client should adopt a
practice of adaptive management in which the implementation of mitigation and management measures are responsive to
changing conditions and the results of monitoring.

2.2. Classification of the habitat and summarization of requirements for implementation of the project
・ Under the WB ESS 6, “habitat” is defined as a terrestrial, freshwater, or marine geographical unit or airway that supports
assemblages of living organisms and their interactions with the nonliving environment. Areas that fall under this definition are
classified into the three habitats below. The Borrower will implement the project while meeting the requirements of each habitats.
1) Modified habitat
Modified habitats are areas where human activity has substantially modified an area’s primary ecological functions and species
composition, such as areas managed for agriculture, forest plantations, reclaimed coastal zones, and reclaimed wetlands. The
Borrower will avoid or minimize impacts on such biodiversity and implement mitigation measures as appropriate.
2) Natural habitat
Natural habitats are areas where human activity has not essentially modified an area’s primary ecological functions and species
composition. Where natural habitats have the potential to be adversely affected by the project, the Borrower will not implement
any project-related activities unless there are no technically and financially feasible alternatives; and appropriate mitigation
measures are put in place, in accordance with the mitigation hierarchy, to achieve biodiversity offset.
3) Critical habitat
Critical habitats are defined as areas with high biodiversity importance or value, including:
(a) habitat of significant importance to Critically Endangered or Endangered species, as listed in the IUCN Red List of threatened
species or equivalent national approaches;
(b) habitat of significant importance to endemic or restricted-range species;
(c) habitat supporting globally or nationally significant concentrations of migratory or congregatory species;
(d) highly threatened or unique ecosystems; and
(e) ecological functions or characteristics that are needed to maintain the viability of the biodiversity values described above in (a)
to (d).
In areas of critical habitat, the Borrower will not implement any project activities that have potential adverse impacts unless all of

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the following conditions are met:
(a) No other viable alternatives;
(b) All due process required under international obligations or national law that is a prerequisite to a country granting approval for
project activities;
(c) The potential adverse impacts on the habitat will not lead to measurable net reduction or negative change in those biodiversity
values;
(d) The project is not anticipated to lead to a net reduction in the population of any Critically Endangered, Endangered, or
restricted-range species, over a reasonable time period;
(e) The project will not involve significant conversion or significant degradation of critical habitats;
(f) The project’s mitigation strategy will be designed to achieve net gains of those biodiversity values; and
(g) A robust and appropriately designed, long-term biodiversity monitoring and evaluation program will be implemented.
Where a Borrower has satisfied the conditions above, the project’s mitigation strategy will be described in a Biodiversity
Management Plan and set out in the legal agreement.
・ ADB and IFC also classify the habitats into three categories, and their definitions are almost the same as the WB. In addition, the
requirements of ADB and IFC for the Borrowers/clients in carrying out the projects in areas of critical habitats are similar to those
of the WB.
・ BMP
・ Under the WB ESS 6, where significant risks and adverse impacts on biodiversity were identified, the Borrower will develop
and implement a BMP. (ESS 6, para 9) BMP includes objectives of biodiversity management, contents of activities,
mitigation measures, implementation schedule, organization structure and responsibility system, and cost. (ESS 6, Appendix
1)
・ ADB SPS has no description of biodiversity management plans and its action plans.
・ Under IFC PS 6, when implementing the project that might cause impacts on important habitats, mitigation measures will be
complied in the Biodiversity Action Plan.
・ Biodiversity offsets
・ In the WB ESS 6, it is stipulated that biodiversity offsets will be considered as a last resort, only if significant residual
adverse impacts remain after all technically and financially feasible avoidance, minimization, and restoration measures were
considered. (ESS 6, para15) A biodiversity offset will be designed and implemented to achieve measurable, additional, and
long-term conservation outcomes that can reasonably be expected to result in no net loss and preferably a net gain of
biodiversity. (ESS 6, para16)
・ Under the ADB SPS, if some residual impacts are likely to remain significant after implementation of avoidance,
minimization and mitigation, the appropriate compensatory measures such as biodiversity offsets will be implemented as a
last resort, to achieve no net loss or a net gain of the affected biodiversity. (SPS Appendix 1, para 13, para 24)
・ Under the IFC PS 6, the mitigation hierarchy includes biodiversity offsets, which may be considered only after appropriate
avoidance, minimization, and restoration measures were applied. A biodiversity offset should be designed and implemented
to achieve measurable conservation outcomes that can reasonably be expected to result in no net loss and preferably a net
gain of biodiversity; however, a net gain is required in critical habitats. (para 10)

2.3. Definition of Protected Area and requirements for implementation of the project
・ In the WB ESS 6, protected areas are areas designated by the government for the protection of long-term nature, its ecosystem
services and cultural values. They also include internationally recognized areas. Examples of a protected area recognized
internationally are not only the site on the World Heritage List created under the World Heritage Convention of the UNESCO,
Biosphere Reserves of UNESCO, the Ramsar Convention Wetland, but also KBA, IBA and Alliance for Zero Extinction Sites.
Even in the protected areas, it is not prohibited to carry out projects, but needed to meet certain requirements for its
implementation.
・ Under the WB ESS 6, the Borrower will carry out the project to the extent that it matches the legal status and the purpose of
protection if the project is implemented in protected areas or the project may affect protected areas. The borrower will prepare
mitigation measures based on the impact assessment and consider not to lose the integrity of the protected area, purpose of its
protection, and the biodiversity of the area. If the project site falls into any of the three habitat areas mentioned above, the
Borrower will need to meet the requirements for protected areas in addition to the requirements for the concerned habitat.
・ Demonstrate that the proposed development in such areas is legally permitted;
・ Act in a manner consistent with any government recognized management plans for such areas;
・ Consult and involve protected area sponsors and managers, project-affected parties including Indigenous Peoples, and other
interested parties on planning, designing, implementing, monitoring, and evaluating the proposed project, as appropriate; and
・ Implement additional programs, as appropriate, to promote and enhance the conservation aims and effective management of
the area.

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・ The ADB SPS states “Legally Protected Areas”, while its definition and examples were not described. (SPS, Appendix 1, para 30)
・ In the IFC PS 6, it is stipulated that, in circumstances where a proposed project is located within a legally protected area or an
internationally recognized area, the client will meet the requirements applicable to the projects. In addition, the client will meet the
following four conditions (para 20):
・ Demonstrate that the proposed development in such areas is legally permitted;
・ Act in a manner consistent with any government recognized management plans for such areas;
・ Consult protected area sponsors and managers, Affected Communities, Indigenous Peoples and other stakeholders on the
proposed project, as appropriate; and
・ Implement additional programs, as appropriate, to promote and enhance the conservation aims and effective management of
the area. (Implementing additional programs may not be necessary for projects that do not create a new footprint.)
・ In the current JICA GL, it is stipulated that projects must, in principle, be undertaken outside of protected areas that are
specifically designated by laws or ordinances for the conservation of nature or cultural heritage, and projects are also not to
impose significant adverse impacts on designated conservation areas.

2.4. Application of SGP to the supply chain


・ Approaches of WB, IFC and ADB are as follows:
・ In the WB ESS 6, it is stipulated that, where a Borrower is purchasing natural resource commodities, that are known to
originate from areas where there is a risk of significant conversion or significant degradation of natural or critical habitats,
the evaluation and verification practices of the environmental and social aspects of the primary suppliers will be confirmed.
(ESS 6, para 38) In addition, it is required that the Borrower will (1) identify where the supply is coming from and the habitat
type of the source area; (2) where possible, limit procurement to those suppliers that can demonstrate that they are not
contributing to significant conversion or degradation of natural or critical habitats; and (3) where possible and within a
reasonable period, shift the Borrower’s primary suppliers to suppliers that can demonstrate that they are not significantly
adversely impacting these areas.
・ However, it should be noted that the ability of the Borrower to fully address these risks will depend upon the Borrower’s
level of control or influence over its primary suppliers. (para 40)
・ IFC, like the WB requires to confirm the evaluation and verification methods of the environmental and social aspects of the
primary suppliers. In addition to the three points in the WB ESS 6, a continuous review of the client's primary supply chains
is required. However, it should be noted that the ability of the client to fully address these risks will depend upon the client’s
level of management control or influence over its primary suppliers. (para 30)
・ No stipulation in the ADB SPS.

2.5. Illegal behavior other than illegal logging


・ There is no stipulation clarifying illegal actions harmful to ecosystem in the WB ESS6.
・ In the ADB SPS, production of or trade in wildlife or wildlife products regulated under the Convention on International Trade in
Endangered Species of Wild Fauna and Flora is not eligible for ADB financing.
Recommendation from the working group meetings for reexamination ・ No stipulation clarifying illegal actions harmful to ecosystem in the IFC PS 6.
of JICA GL Operation
【Protected areas specifically designated by laws or ordinances for the 3. Refer to “2.6 Laws, Regulations and Standards of Reference”
conservation of nature or cultural heritage】
4. As the FAQ of the JICA GL explains the “conditions” to be 4. Based on the recommendation from Advisory Committee for reexamination of JICA GL Operation, it was added in FAQ that
“specifically designated area,” it is suggested that specific examples of areas whose conservation of nature is of international importance include areas listed on the World Heritage List of
examples should be described in the FAQ for better understanding. the UNESCO Convention Concerning the Protection of the World Cultural and Natural Heritage, UNESCO Biosphere Reserves
5. First, the protected areas need to be identified by the national and Wetlands of International Importance In addition, areas whose conservation of cultural heritage is of international importance.
legislations of the borrower government. If such a legislation is not In addition, the areas listed on the World Heritage List of UNESCO Convention Concerning the Protection of the World Cultural
available, it should be discussed whether IUCN rules can be and Natural Heritage were stated as the examples of areas whose conservation of cultural heritage is of international importance.
applicable. In addition, whether the protected areas need to be
identified by IUCN rules should be described. 5. Based on the recommendation from Advisory Committee for reexamination of JICA GL Operation, as described in 2 above, it was
6. Not only the protected areas designated by the central government added in FAQ that the protected areas are the area designated as such by the country and/or local governments by laws and/or
legislation, but also the designated areas by the ordinance or others ordinances to protect nature and cultural heritage. And additional note saying whether or not the area where a project for which
of the local governments should be considered as “protected JICA cooperates is implemented may fall under the areas designated for the conservation of nature or cultural heritage needs to be
areas”. rationally decided by referring to the IUCN protected area management categories, etc., and considering regional characteristics.
7. It is necessary to judge rationally whether and to which extent the
protected area can be developed for each project in accordance 6. Based on the recommendation from Advisory Committee for reexamination of JICA GL Operation, it was clarified in FAQ that
with the conditions specified by the national legislation of the protected areas that are specifically designated by laws or ordinances for the conservation of nature include areas designated by
the country and/or local governments by laws or ordinances primarily for the conservation of nature.

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borrower’s country.
7. Based on the recommendation from Advisory Committee for reexamination of JICA GL Operation, it was added in FAQ that “it
【Project implementation conditions in “area designated specially for needs to be rationally decided considering regional characteristics”.
nature protection and cultural heritage protection”】
8. In consideration of the provision, “[p]rojects must, in principle, be 8. Based on the recommendation from Advisory Committee for reexamination of JICA GL Operation, it was clarified in FAQ that,
undertaken outside of protected areas that specifically designated referring to IFC‘s standards, JICA requires project formation and implementation in such areas (the area designated as such by the
by laws or ordinances for the conservation of nature or cultural country and/or local governments by laws and/or ordinances to protect nature and cultural heritage) to fulfill all conditions.
heritage” (hereafter called the designated area) under the JICA GL,
it is necessary to explain that the project implementation in the 9. As stated in item 8. above, there is an exception to the rule.
designated area is not expected.
9. However, it is also important to enable project formation, if JICA 10. The project site of North-South Expressway Construction Project (Ben Luc - Long Thanh Section) in Viet Nam (Project No.24) is
can justify the background and reasons for implementing the located approximately 12 km north of the Can Gio Mangrove protected forest (center part). It passes through the transition zone
project in the designated area. around the protected forest, since it is permitted to implement the development projects in the transition zone under the domestic
10. Although the JICA GL define the protected areas mean “the law. Therefore, the project was implemented by acquiring the permission from the Provincial People's Committee and Provincial
protected area that are specially designated by laws or ordinances Conservation Forest Management Office.
for the conservation of nature or cultural heritage”, but it is
necessary to consider that there are different contents of the laws 11. Among the reviewed projects, there was no such practice.
and institutions for the protected area management in countries
(For example, some countries have the legislation that allows a 12. In reference to the results of the review survey, examples will be described in the FAQ in the future.
certain development in the designated areas, such as buffer zones
or places where the degree of protection is not high, if the project 13. Among the projects targeted for review, five projects were identified where there are likely to be critical natural habitats in the
meets the criteria). project area. In another 3 projects, preservation measures and monitoring plan were prepared while the environmental monitoring
11. There are some issues raised at the international conferences, etc. has not been conducted. In the SGP of MDBs such as WB, IFC, ADB, no specific reference to habitats such as “ocean” or
that the borrower government changed the designated areas so that “highlands” were not confirmed.
the project can be implemented in “the area designated as such by
the country and/or local governments by laws and/or ordinances to 14. No applicable cases were identified in the projects targeted for review.
protect nature and cultural heritage”. Therefore, it is necessary to
take a careful response recognizing the issue. 15. Under the WB ESS 6, definition of the protected area is expanded, and KBA is included in the internationally recognized
protected areas. On the other hand, under JICA, whether or not the area correspond to the critical natural habitats is judged based
Recommendation from the 2nd & 6th WG on the impacts of each project and its risk. This issue will be discussed under the Point of Argument “the WB ESS6 reference to
【Critical natural habitats】 【Natural habitats】 definition of habitats and protected areas, and risk management approach.”
12. As for “Critical natural habitats”, specific examples should be
described for better understanding. 16. Based on the recommendation from Advisory Committee for reexamination of JICA GL Operation, JICA’s understanding was
13. In the JICA GL , although “critical forests” are listed together with described in FAQ taking into account areal point of view and qualitative point of view as follows:
“critical natural habitats”, environmental and social impacts on Based on the definition by the WB’s Social and Environmental SGPs, etc., JICA defines “significant conversion” and “significant
areas other than forests such as the “ocean” and “highlands” should degradation” to be caused by the implementation of projects as below. Note that whether or not the project for which JICA
also be taken into consideration. cooperates will involve “significant conversion or significant degradation” of critical natural habitats and critical forests needs to
14. “Critical natural habitats” are defined in the “Ecosystems and be decided rationally by considering the content of the project and regional characteristics of the project site, etc.
Biota” in the JICA GL; however, it should be considered from the Significant conversion: Elimination or severe reduction of the integrity of a critical natural habitat or critical forests
aspects of “local communities” and “social environment”. Significant degradation: Substantial reduction of a critical natural habitat’s or critical forest’s ability to maintain viable
15. The “Key Biodiversity Area (KBA)” which was developed with populations of its native species or substantial reduction of key ecosystem functions
reference to the IUCN Red List can be used as a list showing
critical natural habitats. 17. Among the projects targeted for review, five projects were identified that the project area corresponded to natural habitats;
however, none of the projects involves significant conversion or deterioration. Though a part of the project implementation area
corresponded to tree land, tidal flats, marshes, etc. “land clearing; replacement of natural vegetation, permanent flooding such as
【Significant conversion and significant degradation】
by dam, drainage, dredging, filling, or channelization of wetlands” wouldn’t be planned to be implemented. Although OP4.04
16. JICA’s interpretation should be taken into account that
Annex A included an example of significant conversion, ESS 6 does not include any example.
“conversion” represents a negative impact from an areal point of
view, while “degradation” represents a negative impact from a
18. Based on the recommendation from Advisory Committee for reexamination of JICA GL Operation, it is stated in FAQ that
qualitative point of view.
whether or not the project for which JICA cooperates will “involve significant conversion or significant degradation” of critical
17. As it is specified in the WB's OP 4.04 Annex A, “significant
natural habitats and critical forests needs to be decided rationally by considering the content of the project and regional
conversion may include, for example, land clearing; replacement of
characteristics of the project site, as shown in item 16 above.
natural vegetation, permanent flooding such as by dam, drainage,
dredging, filling, or channelization of wetlands, or surface mining,”
19. Based on the recommendation from Advisory Committee for reexamination of JICA GL Operation, it was described in FAQ that
some examples should be described in the FAQ of the JICA GL.
after confirming that no feasible alternatives are available in areas other than “critical natural habitats”, JICA, referring to IFC’s
In addition, it includes the “significant conversion” of “ecosystems
standards, considers that it is important to fulfill all conditions listed below during project formation and implementation, which
not only in land areas but also in water areas” due to serious
shows the requirements for the project implementation and explains that project implementation is not a premise.
pollution and others.

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18. It is necessary to judge rationally whether the project will cause 20. Among the projects targeted for review, there were no cases where project formation was not possible because the project area
“significant conversion” or “significant degradation” from the was located in the critical natural habitats. In addition, the definition of natural habitats and the requirements for project
background and the contents of each project. implementation are specified in the WB ESS6, as described in 【Classification of the habitat and summarization of requirements
for implementation of the project】 on page 22.
【Conditions for project implementation in “Critical natural habitats”】
19. In consideration of the stipulation in the JICA GL that “[p]rojects 21. In the WB ESS 6, it is stipulated as requirements for project implementation in the critical habitats that the project is not
must not involve significant conversion or significant degradation anticipated to lead to a net reduction in the population of any Critically Endangered, Endangered, or restricted-range species, over
of critical natural habitats and critical forests”, it is necessary to a reasonable time period. In addition, in IFC PS 6, it is stipulated that the project does not lead to a net reduction in the population
explain that the project implementation in the critical natural of any CR or EN over a reasonable period of time. In response to these requirements, JICA also stipulates requirement for project
habitat is not expected. implementation that the project does not lead to a net reduction in the population of endangered species IA/IB (CR/ EN).
20. However, it needs to be carefully examined whether the JICA GL
have requirements which make JICA’s project implementation 【Discussion point raised by the Advisory Committee】
impossible in the critical natural habitats in practice. “Ecosystem services in the paddy fields“ December 2, 2016, Phnom Penh – Bavet Expressway Development Project in Cambodia
21. It is necessary to carefully examine whether the JICA GL include (Preparatory survey (ODA loan)) from working group on draft final report
“Endangered species II (Vulnerable: VU)” and “Near Threatened: “Most of the land temporarily used as a soil pit for this project is likely to be paddy field. It was pointed out that regarding secondary
NT” which are classified as per the category of Japanese Ministry nature generated by human usage such as paddy fields and satoyama, how to evaluate its ecosystem services and the impacts of
of Environment in endangered species, in addition to “Endangered projects is a forthcoming issue in JICA's environmental and social considerations.”
species IA/IB (Critically Endangered: CR and Endangered: EN)”
as for the JICA GL’s stipulation of “the list of endangered species
in which projects shall not cause net reduction over a reasonable
period”. It is important to ensure that the effort of the study and
project does not increase and practical measures are taken in
implementing mitigation measures and monitoring.

Social Acceptability 1. Confirmation of records of stakeholder meetings 1. Records of stakeholder meeting Implementation of
1) Dates of announcement and implementation ・ Because requirements on stakeholder analysis were not clarified under the JICA GL, the EIA regulations, the WB OP and so on, stakeholder analysis
2) Place there were only a few cases that the results of analysis were recorded clearly in the EIA and/or the RAP even though stakeholder
3) Method of consultation (community assemble, individual interview, analysis were practically implemented. Implementation of stakeholder analysis was not identified from EIAs and RAPs in the ESS 10 Necessity of
language) review of the 90 projects, but it was confirmed that stakeholder analysis was implemented in 16 projects. reference to Stakeholder
4) Considerations for socially vulnerable groups ・ The number of participants in each consultation meeting varied from project to project. In addition, the number of projects Engagement Plan
5) Method of announcement affected people varies depending on the project, and the geographical distribution of the affected people also varies greatly
6) Participants (the number of people, percentage of affected people, depending on the nature of the project. Therefore, it is difficult to set an appropriate indicator of the number of participants per
affiliation, gender, etc.) session. On the other hand, there was a record that more than 500 people participated in a consultation meeting. In order to secure
7) Contents of discussions (project area, project plan, issues and needs meaningful participation, it is better to consider taking measures such as distribution of information materials or increase of the
from local residents, etc.) number of staffs.
8) Comments from participants ・ It was difficult to find the records of the survey items on the stakeholder consultation from EIAs and RAPs. In some cases, the
9) Reply by project proponents etc. information of the method of invitation, the timing of invitation, participants by gender, participation rate of PAH, etc. was not
10) Result of reflection of received comments to the plan and project included. In addition, the record of language to be used for discussion was not recorded in some RAPs, although local official
11) Preparation of Minutes of meeting languages should usually be used in many cases.
The records of consultations during the preparation of EIA and RAP were included in EIAs and RAPs, but it is an issue that
explanations such as about what was the reason to select the date, time and place for the meeting and why FGD was necessary, in
addition to the records of the minutes of the discussion and the breakdown of the participants, were not sufficiently described in
EIAs and Preparatory Survey Reports.
・ There were also projects (Project Nos.17 and 32) in which the number of meetings was increased more than originally planned in
order to encourage more PAHs participation and to deepen PAHs understanding.
・ As measures to address concerns that may hold down the views of stakeholders with different interests, especially socially
vulnerable groups, there were also some cases that discussions and FGDs were held for specific groups only.
・ For example, in the Project No.2, individual interviews were implemented and also FGDs were held targeting people making
incense sticks at home work, people bathing in the Kelani River, three-wheel taxi drivers, and school children. In the Project
No.32, additional discussions were held only for the Bengali community where there were many non-formal residents.
2. Confirm if any third party raise an issue on the project in terms of
2. Reasons of request from the third party about stakeholder meeting
social acceptability and its reason (e.g. a need for more detailed
・ There were five projects (Project Nos.4, 6, 9, 13, 19) in total in which external indications were recorded. Among the projects
descriptions in the JICA GL, an interpretation problem of the JICA
targeted for review, there were four projects (Project Nos.4, 12, 26, 83) in which objections were filed to JICA, and two projects
GL, a capability/manpower/resource problem, etc.).
(Project Nos. 4, 83) in which investigation was implemented by the Examiners for the Guidelines. Although it was concluded that
there was no violation of the JICA GL in both projects, the examiner gave advice for solving the problem in order to promote the

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response based on the JICA GL philosophy etc.

3. Summarize considerations for socially vulnerable groups. 3. Cases of consideration for socially vulnerable groups
・ Among the 90 projects excluding the 10 of Category C Projects, plans on considerations to socially vulnerable groups were
developed in 60 projects. There were 30 projects in which the plans on considerations were not prepared including seven projects
of Category FI and the projects in which socially vulnerable groups were not identified because the projects were to be
implemented in the existing facilities. In the plans on considerations to socially vulnerable groups, generally financial assistances
related to income, food expenses, medical expenses etc. were planned.
Recommendation from the working group meeting for reexamination of
JICA GL Operation 【Additional Survey Items】Stipulation of WB ESS 10 about stakeholder consultations
【Stakeholder consultation in consideration of socially vulnerable Refer to 2.4 Consultation with local stakeholders.
groups】
4. It is suggested to consider more specific measures in conducting 4. Among the reviewed projects, the followings were confirmed as a method of stakeholder consultation in consideration of the
stakeholder consultation with socially vulnerable groups as the socially vulnerable groups.
future agenda (following specific points were proposed).  In Project Nos.1, 17 and 32, additional stakeholder consultations were conducted in response to the request from the residents,
 To consider a mechanism to bring in people who could not because there was a recognition that the provision of information to the participants was insufficient.
attend the stakeholder consultation and to explain remaining In the stakeholder consultation of the original plan, it was judged that the provision of information was insufficient.
issues that could not discussed in the stakeholder consultation.  In relation to stakeholder involvement, under the WB ESS 10, development of a stakeholder engagement plan and stakeholder
 To set the expected maximum number of participants per analysis, and meaningful participation of the stakeholders through them is required.
meeting to ensure meaningful participation if the number of  In Project Nos.23, 29 and 32, focus group discussions were held in order to discuss with local residents in detail.
stakeholders is large.
 To pay attention when stakeholders who have different interests 【Point of argument created at the Advisory Committee】
are invited together because it might fail to elicit frank opinions From the Working Group on “ ‘Person with disabilities’ written in Chinese characters,” Draft Final Report of the Mega Manila Subway
from stakeholders in such a situation. Project in the Philippines on September 4, 2017.
“… Furthermore, while it is described in Section 2.5.2 [in the JICA GL] that persons with disabilities is included in vulnerable social
groups who should be given special attention, it is described in item 2 of the Social Acceptability in Appendix 1 that vulnerable social
groups include “women, children, the elderly, the poor, and ethnic minorities” and does not specify persons with disabilities. Therefore,
the Advisory Committee member suggested that this point could be a topic of argument for the revision of the JICA GL in the future.
Ecosystem and Biota 1. Summarize practices of the project which was implemented in the 1. Summarization of practices of the project which was implemented in the critical natural habitats. WB ESS 6 Reference to
critical natural habitats. (including justification, any projects in the ・ Among the reviewed projects, 5 projects are located in critical natural habitat. In any case, there is no significant conversion or definition of habitats
critical natural habitats other than forests, consideration status on deterioration, and mitigation measures such as conservation planning and protected areas, and
biodiversity conservation areas, impact on the local community risk management
and impact on natural habitat caused by the local community, 2. Summarization of practices of the project which was implemented in accordance with “conditions to implement the project in the approach
impact on social environment and impact on natural habitat caused critical natural habitat”
by social environment) ・ Among the reviewed projects, 5 projects are located in critical natural habitat. For 2 projects (Nos. 33 and 44), conditions to
2. Summarize practices of the project which was implemented in implement the project in the critical natural habitat were checked as specified in the FAQ of JICA GL. Remaining three projects
accordance with “conditions to implement the project in the critical (Nos. 12,16, and 20) are not subject to these conditions since the environmental reviews were conducted for the projects before
natural habitat” these conditions were specified by JICA. In any case, there is no significant conversion or deterioration, and mitigation measures
3. Summarize practice of WB, ADB and IFC on projects which such as conservation planning
involves “critical natural habitats” and “significant conversion or
significant degradation” 3. Practices of WB, ADB and IFC on projects which involve “significant conversion or significant degradation” of “critical natural
4. Confirm if any illegal logging of the forest was practiced. habitats and critical forests.”
・ Refer to “2. Summarization of practices of WB, ADB and IFC on cases of which project area was in “protected areas that are
specifically designated for the conservation of nature or cultural heritage.” in the upper row (Laws, Regulations and Standards of
Reference).

4. Confirmation of existence of illegal logging


・ Illegal logging was not identified in reviewed 90 projects.
Involuntary 1. Confirm preparation and disclosure status of RAP and records of 1. Preparation and disclosure of RAP, consultation meeting (including the meeting contents, language, mode of the consultation) WB ESS 5 Annex 1
Resettlement consultation meetings (including the meeting contents, language, ・ In the JICA GL, it is stipulated that “for projects that will result in large-scale involuntary resettlement, resettlement action plans Reference of the
mode of the consultation) must be prepared and made available to the public.” and “it is desirable that the resettlement action plan include elements laid out elements of RAP
2. Confirm if involuntary resettlement and loss of means of livelihood in the WB SGP, OP 4.12, Annex A”. Out of 90 projects (except for 10 Category C projects), RAP/ARAP was developed in 39
were avoided and minimized, and effective measures were taken projects out of 44 projects that involve land acquisition. For the remaining five projects, RAP/ARAP has not been prepared, but it
on agreement with affected people in documents. was confirmed that land acquisition and involuntary resettlement would be implemented based on the domestic law and the JICA
3. Confirm the expected number of project affected people at the GL. In addition, after confirming compensation policy and implementation records of stakeholder consultation through the
environmental review stage. environmental checklist, JICA agreed with the project proponent.
4. Confirm the number of actual project affected people at the

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monitoring stage. 2.Confirmation on whether involuntary resettlement and loss of means of livelihood were avoided and minimized, and effective
5. Contents of compensation at the environmental review stage. measures were taken on agreement with the affected peoples in documents
(Timing of compensation, calculation method of compensation rate ・ Among the 37 projects that involve involuntary resettlement, the agreement was confirmed in the document, and the effective
including full replacement cost, measures for recovering livelihood measures for avoidance and mitigation of the impacts were planned and taken in 28 projects. Regarding remaining nine projects,
and other supports.) the plan was prepared but they are not in the implementation stage (resettlement has not been implemented, etc.).
6. - (Only for the projects subject to the field survey)
Confirm if resettled people have improved their standards of living, 3. Confirmation of the estimated number of the affected people at the environmental review stage
income opportunities, and production levels or at least restored ・ The estimated number of the project affected people at the environmental review stage was confirmed for all 37 projects involving
these to pre-project levels involuntary resettlement.
7. Confirm status of establishment of grievance mechanisms.
4. Confirmation of the number of the affected people at the monitoring stage
・ Among the 37 projects that involve involuntary resettlement, the number of the affected people was confirmed at the monitoring
stage in 32 projects (remaining seven projects are not at the monitoring stage, or did not involve involuntary resettlement. In 11
projects, the number of the affected people was different between estimates at the planning stage and actual figures in the
monitoring stage. The numbers increased in the monitoring stage in seven projects, while decreased in four projects. This is
mainly because changes of project design during the detailed design stage and the clarification of the scope to be affected by the
result of detailed census survey.

5. Confirmation of contents of compensation at the environmental review stage


・ In all projects involving involuntary resettlement, the payment of compensation at full replacement cost along with the specific
calculation method was agreed based on RAP of projects and discussions at the time of appraisal.

6. Confirmation on whether resettled people have improved their standards of living, income opportunities, and production levels or
at least restored these to pre-project levels.
・ Among the field investigation projects, the investigation results on the five projects in which livelihood restoration support was
implemented are as follows:
 Project No.5- Delhi Mass Rapid Transport System Project Phase 3 in India: External monitoring was carried out based on the
implementation of livelihood restoration program, and no particular problems were reported regarding the development status of
the relocation site and the livelihood restoration situation.
 Project No.13- Indramayu Coal fired Power Plant Project (E/S) in Indonesia: From October 2016 to August 2018, 300 people
participated in the livelihood restoration programs for “agricultural skills“ and “non-agricultural skills“. The programs continue to
be provided. Also, except for access roads and substation sites, continuation of agriculture is permitted.
 Project No.24- North-South Expressway Construction Project (Ben Luc - Long Thanh Section) in Viet Nam: In addition to
compensation based on the replacement cost, livestock etc. were provided to PAHs on request for the initial infrastructure
development after relocation. There were no reports that their income and living standards were declined compared to before,
though there were some reports that some PAHs translated the provided livelihood into cash and used for purposes other than the
original intent in the relocated area where the support was provided.
 Project No.36- Infrastructure Development Project in Thilawa Area Phase I in Myanmar: According to the project proponent, the
monitoring of compensation was conducted at the port area. As for the monitoring of livelihood restoration, although the address
of the PAH was listed in the agreement, the PAH has moved after compensation at the time of monitoring. Even though the
tracking study became difficult, JICA requested to the project proponent to conduct the monitoring of livelihood restoration. Also,
as for electricity projects, monitoring of payment of compensation for cultivation in the land of tower part to two PAHs was
conducted, and it was confirmed that the payment was made without problems. (Agreement with residents were made.)Project
 No.42- Kenya-Tanzania Power Interconnection Project in Kenya: As livelihood restoration programs, it was agreed at the time of
appraisal to conduct i) rural electrification, ii) improvement of access road near Arusha substation, and iii) provision of wells. At
the field investigation, the progress of the programs were confirmed as follows: i) rural electrification: A package of rural
electrification was in the contractor’s contract that was concluded, and the areas where the electrification is necessary was under
investigation, ii) improvement of access road near Arusha substation: Construction started on April 15, 2019, iii) provision of
wells near the Arusha substation: It was reported that the water supply around the Arusha substation was already prepared by the
government.
7. Confirmation of GRM establishment
・ Among the 44 reviewed projects which involve land acquisition and are classified as Category A or B, the GRM was established
in 43 projects. 1 project (No.34) is excluded because the E/S loan had been provided but land acquisition has not been started.

【Additional survey items】WB ESS 5 “Land Acquisition, Restrictions on Land Use and Involuntary Resettlement”
・ The scope of application under the WB ESS 5 is land acquisition, involuntary resettlement (including resettlement because of
restriction on land use), restriction on access to land including communal property and so on. (para 4)

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・ Compensation should be at replacement cost and there is no significant change in the definition of “replacement cost“ from
OP4.12. However, where functioning markets exist, replacement cost is the market value as established through independent and
competent real estate valuation, plus transaction costs. On the other hand, where functioning markets do not exist, replacement
cost may be determined through alternative means, such as calculation of output value for land or productive assets. (footnote 6)
・ Compensation standards will be disclosed and applied consistently for each loss of assets/land. A clear basis for calculation of
compensation will be documented, and compensation will be distributed to PAPs in accordance with transparent procedures. (para
13)
・ In the case of physically displaced persons who have no recognizable legal right or claim to the land or assets they occupy or use,
the Borrower will provide arrangements to allow them to obtain adequate housing with security of tenure. (para 29)
・ In the case of projects affecting livelihoods or income generation (economic displacement), the Borrower’s plan will include
measures to allow affected persons to improve, or at least restore, their incomes or livelihoods. (para 33)
ESS 5 Annex 1
・ Under the previous WB SGPs, a RAP is required to be prepared for projects involving more than 200 people’s resettlement, while
an abbreviated RAP is required to be prepared for projects involving less than 200 people’s resettlement. On the other hand, ESS 5
requests to prepare the resettlement plan for all projects involving involuntary land acquisition and resettlement, regardless of its
magnitude and complexity.
・ Among the elements of RAP, the descriptions regarding the asset value evaluation method and transition period are as follows:
 Regarding valuation of and compensation for losses, “the methodology to be used in valuing losses to determine their
replacement cost” and “the proposed types and levels of compensation for land, natural resources and other assets under
local law and such supplementary measures as are necessary to achieve replacement cost for them” are described. (para 10)
 Transitional support will be provided during the transition period to those whose livelihoods will be disrupted. (para 29)
・ Minimum elements of a resettlement plan are described separately for resettlement that involves physical displacement or
economic displacement. When project circumstances require the physical relocation of residents, resettlement plans require
additional information such as transitional assistance, site selection, site preparation, and relocation, housing, infrastructure, and
social services, environmental protection and management, consultation on relocation arrangements and integration with host
populations. (ESS 5 Annex 1 para 17-23) On the other hand, in case that resettlement involves economic displacement, the plan
will include direct land replacement, loss of access to land or resources, support for alternative livelihoods, consideration of
economic development opportunities and transitional support. (ESS 5 Annex 1 para 24-29)
In the IFC PS 5 “Land Acquisition and Involuntary Resettlement”, it is stipulated that, where land acquisition and involuntary
resettlement is unavoidable, the client will explore opportunities to collaborate with the responsible government agency, and, if
permitted by the agency, play an active role in resettlement planning, implementation, and monitoring. (para 13) Though land
acquisition and resettlement are the responsibility of the government, the client is required to collaborate with the responsible
government agency, to the extent permitted by the agency, to achieve outcomes that are consistent with this Performance Standard.
If the government resettlement measures do not meet the relevant requirements of the PS5, the client is required to prepare a
Supplemental Resettlement Plan that will address the relevant requirements of the PS5, and implement and monitor the plan. (para
30-32)
Indigenous Peoples 1. Confirm if there were adverse impacts on indigenous peoples. 1. Impacts on indigenous peoples Necessity of reference
2. Confirm if measures to avoid and minimize adverse impacts were ・ Out of 90 projects (except for 10 Category C projects), impacts on indigenous peoples were identified in three projects (Nos. 32, to the term “Indigenous
examined. 42, 44). Peoples/Sub-Sahara
3. Confirm if indigenous peoples plan was prepared and disclosed. African Historically
4. Confirm if free, prior and informed consent (FPIC) process was 2. Measures to avoid and minimize adverse impacts Underserved Traditional
implemented. ・ In the Appendix A “Environmental and Social Considerations Required for Intended Projects” of the JICA GL, it is stipulated that Local Communities”
any adverse impacts that a project may have on indigenous peoples are to be avoided when feasible by exploring all viable
alternatives. In the three projects in which the impact on residential areas of indigenous peoples was confirmed in this review
study, measures to minimize adverse impacts were proposed in the IPP.
3. Preparation and disclosure of IPP
・ Out of 90 projects (100 projects minus 10 Category C projects), three projects have impacts to indigenous peoples. In one project,
RAP was prepared by incorporating elements of IPP (No.32), IPP framework was prepared in another project (Project No.44) and
in the other project, the VPP was developed (No.42).

4. Implementation of FPIC
・ It was confirmed that the North East Road Network Connectivity Improvement Project (Phase 1) (I) in India (No.32) would affect WB ESS 7 Reference to
people who are recognized as indigenous peoples under the national law. However, IPP was not developed, while the elements of the definition of FPIC
IPP were included in the RAP and FPIC (free, prior and informed consultation) were implemented. It was because PAPs were (Free, Prior, and
included in the majority of population of area and had no system different from the mainstream society and culture. (In other Informed Consent)
projects which was implemented in the same State in India by ADB and WB, RAPs including the elements of IPP were also
developed instead of a stand-alone IPP.) WB ESS 7 Reference to

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・ In the Kenya-Tanzania Power Interconnection Project (No.42), consultations were conducted based on FPIC principles during the the elements of IPP
VPP preparation. At the time of the field survey of this study (April 2019), it was confirmed that VPP was appropriate since the
schedule of the implementation of VPP was consistent with ESMP, and the mitigation measures mentioned in the consultation for
VPP (graves are not to be relocated, snakes should not be killed, circumcision ceremonies should not be disturbed) were
incorporated. In addition, the mitigation measures (do not kill snakes and do not disturb rituals) were also reflected in the form of
a ban on killing animals and cultural consideration in the contract with the contractor.

【Additional Survey Items】ESS 7 “Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local
Communities”
・ At the consultation meeting for introduction of ESF conducted by WB, some stakeholders expressed their concerns that the term
“indigenous people” would trigger conflict between different groups of peoples. Therefore, the title of ESS 7 was changed to
“Indigenous Peoples/Sub-Sahara African Historically Underserved Traditional Local Communities”.
・ The definition of the term “Indigenous Peoples/Sub-Sahara African Historically Underserved Traditional Local Communities”
(hereinafter as “indigenous people”) was not changed from that of “indigenous peoples” in OP 4.10 (ESS 7, para 8)
・ It is stipulated in the WB ESS 7 that the Borrower will develop the plan of mitigation measures which is proportionate to the
potential risks and impacts of the project in consultation with the affected indigenous peoples. (ESS 7, para 13) It is not necessary
to develop the plan independently in the following cases; (1) when indigenous peoples are the sole, or the overwhelming majority
of, the elements of the plan may be included in the overall project design (ESS 7, para 15); (2) in circumstances where the
indigenous peoples live together with other people, a broader integrated community development plan will be prepared, intended
not only the indigenous peoples but also other peoples, addressing all elements of mitigation measures which is proportionate to
the potential risks and impacts on the indigenous people (ESS 7, para 17); (3) in case the indigenous peoples are targeted for land
acquisition and/or involuntary resettlement, the documents based on ESS 5 and ESS 7 can be combined.
・ In the IFC PS 7 “Indigenous Peoples”, it is described that the “indigenous peoples” possess characteristics of self-identification,
collective attachment to geographically habitats or ancestral territories, customary cultural, economic, social, or political
institutions, a distinct language or dialect, often different from the official language or languages of the country or region in which
they reside. (para 5) The client’s proposed actions for impact mitigation will be developed with the informed consultation and
participation of the Affected Communities of Indigenous Peoples and contained in a time-bound plan, such as an IPP, or a broader
community development plan. (para 9) Free, Prior, and Informed Consent (FPIC) is an agreement on the project of a groups of
“indigenous people”, and does not necessarily require unanimity.
・ In the current JICAGL, it is stipulated that efforts must be made to obtain the consent of indigenous peoples in a process of free,
prior, and informed consultation. The definition of FPIC was “Free, Prior, and Informed Consultation (FPIC)” in the previous WB
safeguard policies, while it was changed to “Free, Prior, and Informed Consent” in ESS 7.
・ FPIC does not require unanimity and may be achieved even when individuals or groups within or among affected Indigenous
Peoples/Sub-Saharan African Historically Underserved Traditional Local Communities explicitly disagree. (ESS 7 para25)
Monitoring 1. Confirm if the monitoring plan was prepared. 1. Preparation status of Environmental Monitoring Plan
2. (Other items will be confirmed through the review of Section 3.2.) ・ Out of 90 projects (total 100 projects minus 10 Category C projects), it was confirmed that environmental monitoring plan is
prepared in all projects except for FI projects. For FI project, the institutional capacity of the financial intermediaries to manage
the environmental and social issues are reviewed and thus monitoring plan for subprojects are not prepared at the review stage. As
for the eight projects of Technical Cooperation for Development Planning, drafts of outline of monitoring plans were developed.
Appendix 2. EIA 1. Confirm status of EIA approval, language, information disclosure 1. Confirmation of EIA’s approval, language used, disclosure in the country, and whether photocopy is allowed WB ESS 1 Annex 1
Reports for Category in the borrower’s country, and permission of copying ・ It was confirmed that EIA report is approved and disclosed, and taking photocopy is allowed in all Category A projects except one Reference to
A Projects 2. Confirm if the EIA report includes the items specified in the JICA project (No.34) in which preparation of EIA was supported in E/S Loan and four projects of Technical Cooperation for component of
GL. Development Planning (Project Nos.39, 40, 44, 45) in which only master plan preparation was conducted. About the used environmental and
3. Confirm whether EIA was prepared for projects that were language, it was confirmed that in all projects, EIA reports were written in the official language of the country and/or in a social impact
categorized as “Category A” because of large-scale involuntary language widely used in the country. assessment (ESIA)
resettlement as per the JICA GL (not due to the expected ・ Some project proponents etc. disclose the reports on the website as more people have easy access to the internet. Previously, the
environmental impacts). priority was given to disclosure of the hard copy because the internet availability was not always high or it was costly for the
general public in some countries. These days, however, internet becomes increasingly common and affordable in many countries.
2. Confirmation of whether EIA report includes the items specified in the Guidelines
・ For the category A projects (41 projects in total), it was confirmed that EIA reports covered all items which should be included as
per the JICA GL by the time of the environmental review.
3. Confirmation of EIA preparation for projects categorized as “Category A” because of large-scale involuntary resettlement
・ Out of 90 projects (excluding 10 Category C projects), It was confirmed that there were 6 projects (Nos.2,7,11,27,28,38) that did
not fall under sensitive sectors but had sensitive characteristic as large-scale involuntary resettlement, and were categorized as
Category A. Thus, the EIA was prepared in all 6 projects according to the requirements of JICA GL for Category A project.
・ Contents of ESIA and ESMP are shown in “D. Indicative Outline of ESIA” and “E. Indicative outline of ESMP”, respectively, in

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JICA Study for Review of JICA Guidelines for Environmental and Social Considerations February 2020

Reference: Survey Items Survey Results Discussion Points


Items of Current Including Recommendations from WG on Review of Operation Background and Reasons for Discussion Points (Draft)
JICA GL
Annex 1 of the WB ESS 1.

Appendix 3. 1. Confirm justification of “Sensitive Sectors” 1. Confirmation of justification of “Sensitive Sectors”


Illustrative List of (especially, the scale of impacts of the project in power Among the reviewed projects, projects falling under the category of sensitive sector include No.42 Kenya-Tanzania Power
Sensitive Sectors, distribution, water supply and agriculture sectors which usually do Interconnection Project for “power transmission and distribution lines sector”; No.29 Rengali Irrigation Project (Phase 2), No.40
Characteristics, and not have significant negative impacts if the project does not have Project for Study on Integrated Development of the Adjacent Zones to Yacyreta Dam Reservoir, and No.45 Project on Irrigation
Areas sector-related sensitive characteristics or located in a sensitive Scheme Development in Central and Eastern Uganda for “agriculture sector”.
area) It was confirmed that all these projects had elements that fall into Category A in each sector requirements listed above, and in
addition, these projects were classified as Category A after fully considering the project location and characteristics, etc. Overall,
they were categorized as Category A because these projects are likely to have significant impacts.
Appendix 4. (the screening form will be reviewed when the JICA GL are reviewed)
Screening Format
Appendix 5. (the environmental checklist will be reviewed when the JICA GL are
Categories and Items reviewed)
in Checklist
Appendix 6. Items 1. Confirm justification of monitoring items, reference standards, 1. Rational of selecting monitoring items, reference standards, differentiation of monitoring in construction and operation phases
Requiring preparation of the monitoring plan for construction and operation ・ In EIA, monitoring items for construction phase and operation phase are separately prepared in the monitoring plan.
Monitoring phases. ・ Among 90 projects (excluding 10 Category C projects that do not require monitoring), environmental monitoring is currently
implemented for 51 projects, and submission of monitoring results was confirmed in 50 projects. On the other hand, social
monitoring is being conducted in 30 projects, of which submission was confirmed in 29 projects. (One project where the
submission of both environmental monitoring results and social monitoring results was not confirmed is the project which was
suspended due to a security reason in the host country [No. 38].) Gaps between environmental review results and monitoring
results were identified in five projects. It was mainly due to unforeseen events, including: drainage channel had to be installed
because of the rise of groundwater level which was not expected in EIA (No.6); additional EIA was prepared because the planned
disposal site for dredged soil was occupied by informal settlers and thus additional disposal site was required (No.11).
Others

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JICA Study for Review of JICA Guidelines for Environmental and Social Considerations February 2020

ANNEX: RECEIVED PUBLIC COMMENTS

JICA invited the comments on the "JICA Study for Review of JICA Guidelines for Environmental
and Social Considerations" draft from stakeholders between 16th October and 14th November 2019,
and following comments were received.

A-1
JICA Study for Review of JICA Guidelines for Environmental and Social Considerations
Final Report
Table 1 Comments Received from the Public
No. Relevant Section Comments
1 Impacts on society: Unfair distribution of benefits, local It would be better to start work by telling the local people before the start of the project
interest, and impacts on local economy what the project can do to address the needs of the local people. In Pokhara project now:-
Unfair distribution of benefits, same local interest, and impacts on local economy.

2-1 p.2-7 JICA must take it into consideration a broader pattern of criminalisation and intimidation
“Regarding the ‘2.5 Concern about Social Environment and against Indonesian environmental human rights defenders, including the local farmers
Human Rights’, among 100 reviewed projects, no project was who oppose the Indramayu coal-fired power plant project and were forced to be in jail for
found which was implemented in the countries and areas in 5 to 6 months due to the false charge in West Java, Indonesia. So that JICA could be aware
conflict or areas where the right to basic freedom (e.g. freedom that the freedom of expression has been at stake in Indonesia.
of expression) and legal remedies are restricted.”
(English DFR p.2-7, Japanese DFR p.2-6)
2-2 p. 2-14, 2-15 (4) Environmental and Social Considerations by 1. In Project No. 13 (Indramayu coal-fired power plant project in West Java, Indonesia),
the Project Proponent in the E/S the land acquisition and the construction of the access road and the substation started
“In addition, in case of Project No.13, land acquisition was without “social acceptability” from the local affected community, especially from
carried out and the construction of the access road had been tenant farmers, farm workers and fishermen.
started during the period that the components covered by E/S 2. The compensation payment brought big conflict and confusion among the local
A-2

loan was undertaken. It was confirmed that compensation for affected community, as the compensation for crop was paid through landowners but
land was paid according to the national law prior to land not directly to tenant farmers (no proper consultation with tenant farmers about such
acquisition, partially some bank accounts for compensation compensation) and as the compensation standards for crop have been never
were frozen due to overpayment of the compensation, farming disclosed/disseminated.
is permitted to continue in areas where construction has not 3. The report said that “Farming is permitted to continue” --- It is necessary because the
started yet, and livelihood restoration supports are provided as local tenant farmers and farm workers didn’t and won’t agree the project itself, and
per the Land Acquisition and Resettlement Action Plan their life would be heavily affected and get worse if they cannot continue farming.
(LARAP) such as vocational training on welders and 4. Livelihood restoration supports are not the solution to restore such farmer’s
mushroom cultivation promotion, and employment as project livelihood; even though they could get vocational training on welders, there is no
workers.” certain stable job in the future; mushroom cultivation promotion has been no well-
planned and failed to provide net profit for such program’s beneficiaries; and
employment as project workers is only temporary and is usually limited to only a part
of males, but totally not for females.
5. Before the completion of LARAP, PLN started paying the compensation for land and

Feburary 2020
crops. It proves no appropriate process and participation to make the LARAP.
6. It is not reasonable and not acceptable that JICA has continuously disbursed its E/S
loan for this project, while the project itself has already caused significant damages
to the local community and has violated many provisions of JICA’s Guidelines. Thus,
we strongly recommend that JICA revise the relevant provision of its Guidelines,
JICA Study for Review of JICA Guidelines for Environmental and Social Considerations
Final Report
No. Relevant Section Comments
so that JICA makes sure the fulfillment of environmental and social
requirements under its Guidelines even during the implementation of its E/S
loan.
2-3 p. 2-20 1. One of the villages which are mainly affected by the Indramayu coal-fired power
Project No.13 Indramayu Coal Fired Power Plant Project (E/S) plant is Mekarsari village in Indramayu, West Java, Indonesia. The cultural root for
(Indonesia): the most of Mekarsari villagers is farming, or cultivating land for agriculture. They
“From October 2016 to August 2018, 300 people participated have a strong bond with the land. The loss of the land due to the power plant will
in the agricultural skills-based livelihood restoration programs deprive the villagers of such cultural farming and livelihood. And such impact will
and the non-agricultural skills-based programs, and the lead up to the poverty of the local affected community, especially tenant farmers and
programs have been continuously provided. Additionally, farm workers.
PAHs were allowed to continue farming on the project sites 2. Livelihood restoration programs are not the solution to restore small farmer’s
except for access roads and substation sites.” livelihood; even though they could get vocational training on welders, there is no
certain stable job in the future; mushroom cultivation program as well as catfish
cultivation program has been no well-planned and failed to provide net profit for such
program’s beneficiaries; and employment as project workers is only temporary and
is usually limited to only a part of males, but totally not for females.
3. The report said that “PAHs were allowed to continue farming on the project sites” --
A-3

- It is necessary because the local tenant farmers and farm workers didn’t and won’t
agree the project itself, and their life would be heavily affected and get worse if they
cannot continue farming.
4. The construction of the access road and the substation started without “social
acceptability” from the local affected community, especially from tenant farmers,
farm workers and fishermen. The access roads and substation sites must have been
continuously cultivated by the local farmers till now.
2-4 p. 2-39, 2-40 1. The NGO pointed out since December 2017 about the illegal arrest of the local
No. 13 Indramayu Coal Fired Power Plant Project (E/S) farmers who are protesting against the project.
(Indonesia) 2. The other information and facts here are correct.
“The NGO pointed out since September 2017 that it is not
appropriate to arrest the local residents who are protesting
against the project raised the national flag upside down. The
NGO also pointed out as follows: Though the affected people’s

Feburary 2020
group pointed out issues on the project and submitted letters
showing objection to the project and JICA finance three times,
there was no response from JICA. After the fourth letter was
submitted to JICA, JICA Indonesia office had a meeting with
the group. After that, one more letter was submitted from the
JICA Study for Review of JICA Guidelines for Environmental and Social Considerations
Final Report
No. Relevant Section Comments
group, however there was no response from JICA.”

2-5 p. 2-50 Same as the Comments 2-3.


No.13: Indramayu Coal Fired Power Plant Project (E/S),
Indonesia
“From October 2016 to August 2018, 300 people participated
in the livelihood restoration program of ‘agricultural skills-
based,’ and ‘non-agricultural skills based’. This program is
being provided continuously.”
2-6 p. 3-8, 3-9 As the report mentioned, in October 2018, Intergovernmental Panel on Climate Change
Trends of International Aid (2) The Paris Agreement (IPCC) published a special report on Global Warming of 1.5 C. It has become a common
understanding that the world has no space for any new coal-fired power plant. Thus, we
strongly recommend that JICA revise the relevant provision of its Guidelines, so that
JICA makes sure no more support for any new coal-fired power plant, according to
the international trend.
3 【Original Comment in Japanese】 【Original Comment in Japanese】
レビュー調査報告書 p.2-9 1. No. 4 ティラワ経済特別区開発事業の Zone B について、「出資区域の拡大
A-4

プロジェクトの重大な変更が生じた案件については、2 による『重大な変更』として、実施されている。」と記載があるため、JICA
件が該当した。No.4 では、後発事業である Zone B(フェ ガイドラインの「プロジェクトに重大な変更が生じた場合、改めてカテゴリ
ーズ 2)事業は、出資区域の拡大による「重大な変更」 分類を行い 3.2.1 に従って環境レビューを行う。変更の概要と変更後のカテ
として、実施されている。No.9 については、アクセス道 ゴリ分類を公開し、主要な環境社会配慮文書を入手後速やかに公開する。」
路コンポーネントの設計変更が「重大な変更」とされた。 という規定に基づけば、拡大した区域への「出資」決定時に「環境レビュー」
が行なわれていなくてはならない。その「出資」決定時の「環境レビュー結
果」(事前評価表)はどこで公開されているのか、ご教示願いたい。また、
JICA として、出資を決定した日時もご教示願いたい。
2. No. 4 ティラワ経済特別区開発事業の Zone B について、JICA は出資及び融
資という 2 つの異なる形態で関与をしているが、どちらであったにせよ、大
規模な非自発的住民移転を伴う大規模事業について、一つの事業の「重大な
変更」という認識で開発事業を進めることが妥当であったのか、検証がなさ
れるべきである。こうした検証は、今後、同事業で次期開発区域への拡大が
行われる際の出資決定がどのように行われるべきかを考えるにあたり、極め

Feburary 2020
て重要であると考える。
4 Review report references to Projects No. 4 and No. 36 (Thilawa 1. Report Methodology
Special Economic Zone) 2. Failure to acknowledge correspondence provided to JICA by and on behalf of TSEZ
affected persons from 2014 to date
3. Failures to implement the JICA GLs in the TSEZ
JICA Study for Review of JICA Guidelines for Environmental and Social Considerations
Final Report
No. Relevant Section Comments
a) Failure to comply with environmental and social impact assessment requirements
b) Failure to adequately consult affected villagers
c) Failure to adhere to JICA Guidelines and international standards on resettlement
i. Resettled villagers from Zone A and B have experienced serious deterioration
of their living standards after resettlement
ii. The Resettlement Work Plans and EIAs for Zone A and B both did not
adequately explore alternatives for displacement
iii. Affected villagers from Zone A and B did not have meaningful opportunities
to participate in their resettlement processes
iv. Breach of JICA GLs on the establishment of a Grievance Mechanism
d) Concerns regarding the implementation of the objection procedure

Please find the attached submission together with Annexures 1, 2, and 3.


(*Main topics of the submission are shown in 4-1 to 4-3. Original submission except
Annexures is also attached after this table.)
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JICA Study for Review of JICA Guidelines for Environmental and Social Considerations February 2020

Comment No. 4-1 to 4-3 Original submission except Annexures and personal information

Introduction

JICA has invited public comments on its review of the implementation of the JICA Guidelines for
Environmental and Social Considerations (“JICA GLs”) across its projects over the past ten years, the
“JICA Study for Review of JICA Guidelines for Environmental and Social Considerations Draft Final
Report” (“JICA Review” or “the Review”). The comments below are submitted by EarthRights
International (EarthRights), following consultations with Thilawa Social Development Group (TSDG)
and representatives of the broader Thilawa community based on the environmental and social impacts of
JICA’s projects in the Thilawa Special Economic Zone (TSEZ).

The development and management of the TSEZ has violated Myanmar Law, international law, and the
JICA GLs and project affected persons in the TSEZ have suffered serious environmental and social
impacts as a result. JICA’s Review study, however, only makes brief cursory references to the TSEZ, and
paints an inaccurate picture of the efficacy and implementation of the JICA GLs in the TSEZ. This is
particularly concerning given that EarthRights and other CSOs have submitted comprehensive reports on
the impacts of the TSEZ to JICA from 2014 to date which provide critical insight into the implementation
of the JICA GLs.

EarthRights published a briefing note in 2014 detailing the ways in which the development and
management of the TSEZ violated Myanmar Law, international law, and the JICA GLs. Broadly,
EarthRights noted that JICA had failed to implement its guidelines as follows:

a) Failure to hold stakeholders accountable under the JICA GLs as the body responsible for
ensuring accountability in the implementation of its cooperation project;
b) Inadequate analysis of human rights, environmental and social considerations;
c) Failure to provide timely support and adequate compensation to the resettled community; and
d) Failure to ensure that affected persons were provided with adequate information to participate
in decision making.

Five years later, these same issues persist.

We submit that JICA’s reporting on the TSEZ in the Review is inadequate and that the development and
impacts of the TSEZ, particularly on the livelihoods of affected persons, demonstrate that both the content
and implementation of the JICA GLs need to be strengthened.

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These comments are confined to specific aspects of the TSEZ, and it should be noted that any omission
to directly respond to statements in the JICA Review should not be deemed to indicate our acceptance of
the report’s contents.

These comments are structured as follows:


1. First, we will outline concerns about the methodology of the report.
2. Second, we will detail the key correspondence that has been provided to JICA by and on behalf
of TSEZ affected persons that has not been acknowledged in the report.
3. Third, we will briefly refer to the ways in which the impacts of the TSEZ projects demonstrate
that JICA’s projects in the TSEZ have failed to implement JICA’s Environmental and Social
Guidelines in the following areas:
a) Environmental and social impact assessment requirements;
b) Consultation requirements;
c) Resettlement requirements: including livelihood restoration and the establishment of an
operational grievance mechanism; and
d) Objection Procedures

1. Report Methodology

The report’s description of its methodology is very vague. 1 Members of the TSDG and the community
leaders have raised the question of who the report was drafted by and what process was followed, and this
is not clear from the report itself. 2 This leaves the transparency and independence of the report open to
question, and is counter to JICA GL 2.10.2 which asserts that JICA’s review process is “designed to
ensure transparency and accountability”.

EarthRights, the TSDG and affected community members have corresponded extensively with JICA over
the years (as detailed below) regarding the social and environmental impacts of the TSEZ, yet they were
not consulted in the drafting of the Review Report even though two TSEZ projects are included among
the 100 projects reviewed (referred to as Project No.4 and Project No.
36 in the report). Consultation with these groups in the drafting of the report and proper engagement with
all of the correspondence that has been provided to JICA regarding the impacts of the TSEZ would have
led to a more accurate reflection of the implementation of JICA’s guidelines. The TSDG and affected
community members were also not made aware of this draft report’s publications and they were not
contacted directly for comments on the report.

The scope of the study is confined to 100 out of 1800 projects, yet the report does not describe precisely

1
JICA Report, p15 (1-7).
2
Comments from TSDG in a meeting with EarthRights on Tuesday, 5 November 2019.

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how these 100 projects were selected. This sample of projects may not be representative of all of JICA’s
projects. In the context of the TSEZ, for example, the report acknowledges the significant expansion of
the project area of “Project 4” in the report from Zone A into Zone B, yet the report does not cover any of
the impacts of Zone B even though Zone B consists of an area of over 2000 hectares and comes with
significant impacts.

The report also uses unclear and inconsistent language to refer to the Thilawa projects themselves, which
makes it challenging to respond directly to the limited references in the report. Affected persons and
EarthRights have generally referred to the project areas as Zone A and Zone B, whereas the report refers
to “Class-A” (Project No. 4 in the Report) and “Phase I” (Project No. 36 in the Report). It is not clear to
affected persons which project the Report itself is referring to. The comments that we provide below
therefore relate to both Zone A and Zone B of the TSEZ.

2. Failure to acknowledge correspondence provided to JICA by and on behalf of TSEZ affected


persons from 2014 to date

JICA’s Review Report has failed to acknowledge detailed information regarding the environmental and
social impacts of the TSEZ that has been provided to JICA by and on behalf of affected persons from 2014
to date. The report only acknowledges that JICA has received communication from NGOs regarding the
TSEZ in two cases:

a) Letters regarding the categorization of Thilawa Class A and Thilawa Phase 1 Project:

JICA classified Thilawa SEZ Class A area (Project No. 4 in the Report) as a Category A project (meaning
that JICA deems it to have “significant adverse impacts on the environment and society), while it classified
the Thilawa SEZ Phase 1 Project (Project No. 36 in the Report) as a Category B project (meaning that JICA
believes that the impacts of the project on the environment and society are less serious than a Category A
project).

The report states that JICA received letters from NGOs on 24 May 2013 and on 28 August 2017 stating
that the projects should both be considered to be Category A projects because they are closely related to
each other. 3 The report also states that ‘Some affected families of Class-A who resettled said they were
threatened by the government by saying “Their house will be demolished if they don’t sign an agreement
document for resettlement and compensation” and “if affected people want compensation for land, people
have to go to a court”’ however it does not state how JICA responded to this information.

b) Letter requesting a meeting with JICA in April 2014

3
JICA Review Report, page 14.

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The report states that JICA received a letter from NGOs to request a meeting with JICA about investing
in the development in April 2014, but that JICA did not reply and decided to invest in the project on 23
April 2014. 4

JICA has therefore failed to acknowledge extensive communication and reports from EarthRights, the
TSDG and other stakeholders submitted from 2014 to date.

Key information sources not acknowledged by JICA in the Review Report include:

• EarthRights “Briefer on the Thilawa Special Economic Zone: An Analysis of the Affected
Communities’ Rights and Remedies Under Myanmar Law and JICA’s Guidelines” published in
2014.
• A letter to JICA regarding the outcome of the TSEZ objection procedure submitted to JICA in 2014.
• A report published by Physicians for Human Rights (PHR) in 2014 on the conditions of resettled
villagers from Zone A, noting that several households told PHR that they put their homes up for
collateral, entitled A Foreseeable Disaster in Burma: Forced Displacement In the Thilawa
Special Economic Zone.
• A public statement from the Thilawa community on the failure of JICA and the project proponent
to take into account community voices in the EIA and Resettlement Work Plan (RWP) processes
in 2016.
• Correspondence from the Community Driven Operational Grievance Mechanism (CD- OGM)
Design Committee regarding the proposal for the Thilawa CD-OGM and its development from
2015 to date.
• EarthRights’ analysis of the Thilawa Complaints Management Procedure (TCMP), submitted by
EarthRights to JICA in February 2018.
• A social impact report consisting of a comparative analysis of the socio-economic status of
households which have been relocated by the Thilawa SEZ and those which remained in their
original communities which provides insight into the impact of resettlement as a result of the
TSEZ on community livelihoods, submitted to JICA by Dr. Mike Griffiths, Paung Ku, and
Mekong Watch in June 2018.

Table 1 in Annexure 1 (attached) provides a list of the substantive correspondence that EarthRights,
Mekong Watch, and Thilawa community members have publicised and/or have provided to JICA which
offers insight into the implementation of the JICA GLs. A number of these documents are referred to
below in our description of non-compliance with the JICA guidelines in specific areas.

3. Failures to implement the JICA GLs in the TSEZ

4
JICA Review Report, page 69.

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a) Failure to comply with environmental and social impact assessment requirements

The JICA Review does not make any specific statements about the EIA process in the TSEZ. This is
concerning given that the TSEZ failed to comply with environmental and social impact assessment
requirements in numerous ways, as will be detailed below.

JICA GLs require “project proponents…[to] disclose information about the environmental and social
considerations of their projects” and JICA to provide assistance. 5 The Guidelines define environmental
impacts as “including [impacts on] air, water, soil, ecosystem, flora, and fauna” 6 and social impacts as
including “migration of population and involuntary resettlement, [and] local economy such as employment
and livelihood.” 7

Further, the JICA GLs state that “Projects must comply with the laws, ordinances, and standards related
to environmental and social considerations established by the governments that have jurisdiction over
project sites (including both national and local governments).” In the context of the TSEZ, the 2012
Environmental Conservation Law and the 2014 SEZ Law are relevant. The SEZ Law imposes particularly
a stringent environmental standard, requiring investors to follow “international standards and norms on
environmental protection.” 8

All of these JICA guideline requirements have been violated in Thilawa, as seen from the inadequacy of
the EIAs for Zone A and B. First, due to the lack of clarity on the industries that will be operating in each
zone, the EIAs failed to provide a reliable picture of the full range of environmental impacts that would
result from the TSEZ. Second, both EIAs contained highly insufficient analyses of the impacts on
livelihoods or social issues associated with resettlement.

On the first point, the EIAs for Zone A and B did not properly analyze the environmental impacts that will
result from the Thilawa SEZ. International best practice requires that EIAs are focused, “provid[ing]
9
sufficient, reliable and useful information for development planning and decision- making.”
Unfortunately, both EIAs failed to provide a reliable picture of the full range of impacts that will result
from the TSEZ. For one, they failed to describe the industries that will be operating in their respective
zones. Without knowing exactly what type of industries will operate in the TSEZ, it is unlikely that

5
JICA Guidelines 2.1(1).
6
Id. 1.3 (1)
7
Id. 2.3(1)
8
See SEZ Law § 35.
9
United Nations Environmental Programme (UNEP), “Environmental Impact Assessment and Strategic Environmental
Assessment: Towards an Integrated Approach,” 2004, pg. 94, available at
https://wedocs.unep.org/bitstream/handle/20.500.11822/8753/Environmental_impact_assessment.pdf?sequence=3&
amp%3BisAllowed=

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accurate predictions on environmental, social and economic impacts of the project were made. 10 Despite
this inadequate assessment, JICA failed to hold the Project Proponent accountable.

On the second point, the EIAs were extremely lacking in their analyses of economic impacts caused by
the TSEZ. Both EIAs simply conclude that the project would be beneficial to the local economy because
it will bring more jobs, without backing this conclusion up with any evidence. 11 According to international
best practice, a proper economic impacts analysis must consider the following variables: “duration of
construction and operational periods; workforce requirements for each period and phasing of construction
workforce; needs (numbers to be employed during the peak phase for construction works); skill
requirements (local availability); earnings; raw material and other input purchases; capital investment;
outputs; and the characteristics of the local economy.” 12 Except for the first and last factor, the EIA did
not provide any information on these crucial elements, nor did it provide any data on why the TSEZ is
expected to have a beneficial impact on the local economy.

Given the inadequate amount of information used in the analysis for the EIAs, the Project Proponent has
not conducted an adequate social impact assessment as required by JICA GLs and international best
practice. JICA should have held the Project Proponent accountable on this matter yet failed to do so, yet
this has not been acknowledged in the JICA Review Report.

b) Failure to adequately consult affected villagers

The JICA Review Report does not provide specific details on its adherence to its guidelines regarding
consultation in the TSEZ area at all, therefore we wish to provide further detail and context in this regard.

In the JICA GLs, JICA states that “[d]emocratic decision-making is indispensable for environmental and
social considerations,” and that “[i]t is important to ensure stakeholder participation, information
transparency, accountability, and efficiency, in addition to respect for human rights, in order to conduct
an appropriate decision-making process.” 13 Further, the GLs note – as one of its seven most important
principles – that “JICA asks stakeholders for their participation,” “incorporate[ing] stakeholder opinions
into decision-making processes regarding environmental and social considerations by ensuring the
meaningful participation of stakeholders in order to have consideration for environmental and social
factors and to reach a consensus accordingly.” 14

10
Zone B EIA lists the industries currently operating in the Thilawa SEZ on Table 2.7-2. On page 7-42, the EIA states that
“as of March 2016, there is no clear information about what kind of industries will move into the Thilawa SEZ Zone B but it
is assumed that almost the same type of industries as in Zone A will move into Zone B.”
11
See Zone B EIA, pg. 7-66; Zone A EIA, pg. 7-45.
12
The UNEP report on international best practice on EIAs states that “[w]ithout reliable information on these factors it is
very difficult to implement an economic impact assessment. It is vital to attempt to obtain such data – if this does not occur,
then not only economic impacts but also social and health impacts will not be predicted adequately.” UNEP, “Environmental
Impact Assessment and Strategic Environmental Assessment: Towards an Integrated Approach,” 2004, pg. 142.
13
JICA Guidelines 1.1.
14
JICA Guidelines 1.4.

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For Category A projects like the TSEZ, “JICA encourages project proponents etc. to consult with local
stakeholders about their understanding of development needs, the likely adverse impacts on the
environment and society, and the analysis of alternatives at an early stage of the project, and assists project
proponents as needed.” 15 Further, JICA itself is required to gather stakeholder opinions. 16

None of these guidelines were properly followed in the context of the TSEZ, particularly in relation to EIA
consultations and disclosure for both Zone A and B. In both processes, consultations were not effectively
advertised, local stakeholders (including NGOs) were not adequately involved, participation at the
consultations were insufficient, and the EIAs themselves were not disclosed in an accessible manner.
JICA’s statement in the review report that “[r] Regarding approval, disclosure and availability of copying
EIAs, it is confirmed that all category A projects except 5 projects [Thilawa not listed among these
exceptions] fulfilled these requirements” is therefore not accurate. 17

First, the EIA for Zone A failed to mention whether one of the most crucial project-related information,
the draft of the EIA, was ever disclosed to the public. Without the opportunity to access the EIA draft, it
is not possible for local stakeholders to have meaningfully contributed to its drafting. Furthermore, the
consultations for the Zone A EIA were not adequately advertised. Zone A EIA simply states that
“township officer informed to the local residence” about the consultations. 18 To comply with JICA’s
requirement on meaningful stakeholder participation, many more means should have been employed to
disclose the consultation schedule. Given the dearth of proper information-sharing, it was unsurprising
that no affected villager participated in either of the consultations for the Zone A EIA. 19 Since none of
the villagers were properly consulted, it was clear that Project Proponent failed to meet the requirement
of meaningfully incorporating villagers’ views in designing the EIA and EMP for Zone A, and JICA
likewise failed to meet its own requirement of involving stakeholder views in decision-making.

As for the Zone B EIA, while the report contains more evidence of participation from affected villagers,
it similarly suffered from a lack of information-sharing platforms. 20 The EIA stated that the scoping report
and draft EIA report were shared at public places, but failed to mention any media outlets or online
platforms. The public places where the reports were disclosed were mainly administrative offices, not
places of frequent public gatherings such as libraries and community halls. 21 Therefore, it is unlikely that

15
JICA Guidelines 2.4.4.
16
JICA Guidelines 3.1.2.3.
17
JICA Review, p 51 (2-22).
18
See Zone A EIA, pg. 10-1.
19
While the EIA report claimed that 6 villagers participated in the second consultation, EarthRights found that three are
village administrators and the other three are village heads, all of whom are paid by the government, a project proponent. See
EarthRights International, Analysis of EIA for Phase I of Thilawa SEZ, Nov. 2014, pg. 8, available at
https://earthrights.org/wp-content/uploads/thilawa_eia_analysis.pdf.
20
Unlike the EIA report for Zone A, Zone B’s EIA details a greater number of consultations, provides attendance lists and a
list of villagers’ comments.
21
The list of public disclosure places for Zone B’s EIA can be found in “Table 11.3-5 Summary of Public Disclosure for
Draft EIA Stage” of the report.

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affected stakeholders had adequate access to the information necessary to meaningfully participate in the
consultations.

Furthermore, while the Zone B EIA referred to comments received on the draft EIA report, 22 it failed to
explain what changes were made to the final EIA in response to these comments. Thus, it is unclear
whether the Project Proponents actually complied with the requirement that affected villagers’ views are
incorporated into the EIA, EMP, and overall decision-making process.

Lastly, in the consultations for both EIAs, civil society organizations (CSOs) were not adequately
involved. 23 While Zone B EIA claimed that CSOs were part of the scoping and draft EIA consultations,
the attendance list did not show any CSOs participating. 24 Zone A EIA mentioned that an environmental
consultancy company and an academic institution participated in the consultations, 25 but there was no
evidence of participation from any of the numerous advocacy organizations actively engaged with the
Thilawa SEZ. This is alarming given that the JICA Guidelines define “local stakeholders” as “affected
individuals or groups (including illegal dwellers) and local NGO” (emphasis added). 26

Altogether, it is clear that the JICA requirement of meaningful stakeholder participation was not fulfilled
in the EIA processes for both Zone A and B, due to numerous problems concerning the disclosure of draft
EIAs, advertising of the consultations schedule, and NGO involvement. JICA failed to hold the Project
Proponent accountable for this violation, which is all the more alarming given that the TSEZ is a Category
A Project that requires heightened involvement of local stakeholders.

c) Failure to adhere to JICA Guidelines and international standards on resettlement

In the JICA Review, limited references to livelihood restoration are made 27 as there appear to have been

22
See id., Table 11.3-6 Brief Summary of Public Comments and Responses.
23
The EIA Procedure lists civil society as one of the groups project proponents are required to consult. See EIA Procedure,
§ 50, 61.
24
On page 11-12, the Zone B EIA claims that NGOs participated in the consultations. The attendance lists in Annex 11-3
and 11-8 do not include any civil society organization representatives.
25
See Zone A EIA, Table 10.2-1 and Table 10.3-1.
26
JICA Guidelines 1.3.12.
27
JICA Report statements on the monitoring of compensation and livelihood restoration
a) Livelihood restoration for the port sub-project (Thilawa Area Phase 1):
i) JICA states that the project proponent states that they have completed social monitoring of the compensation
payments. However, JICA says that they have not undertaken monitoring of livelihood restoration because it
was difficult for them to follow up because people from project-affected households moved to different
addresses after they received their compensation. JICA states that it has asked the project proponent to continue
to try to follow up on livelihood restoration. (JICA Review at p39)
ii) JICA also states that, according to the Resettlement Action Plan, the port development section planned to
promote job opportunities for project affected households. However JICA states that affected persons did not ask
for this after their compensation was paid, therefore there has been no livelihood restoration. (JICA Review at
p39 and p74)
b) Compensation and livelihood restoration for the power transmission line and substation subproject: JICA states
that social monitoring of the crop compensation payment to affected households for farmland that was affected by the
transmission towers was completed, and that compensation was paid without any problems. JICA states that the
livelihood restoration was not conducted here because no significant impact on livelihood was expected.(JICA Report
at p14)
c) Compensation and livelihood restoration for the gas pipeline sub-project: JICA states that monitoring for
compensation payment has been implemented, but that follow up surveys for livelihood restoration monitoring were

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insufficient livelihood analysis to date, in spite of the fact that a comprehensive social impacts analysis has
been shared with JICA (Annexure 2 attached). 28 We refer to this report and to the JICA Review’s limited
references to livelihood restoration below where relevant.

The JICA Guidelines contain extensive requirements concerning involuntary resettlement. Key
requirements include: fully exploring alternatives to displacement and avoiding displacement when
possible; 29 appropriate participation of affected people in the planning, implementation and monitoring
of resettlement action plans; 30 and sufficient compensation and restoration of affected people’s
livelihoods. 31 Similar requirements are also found in guidelines from the World Bank, International
Finance Corporation, and the Asian Development Bank, and JICA must “confirm” that projects do not
deviate significantly from such standards. 32

The resettlement process of Zone A and B have not complied with the aforementioned requirements of
JICA Guidelines and international standards. Each of the requirements will be examined separately below.

i. Resettled villagers from Zone A and B have experienced serious deterioration of their living
standards after resettlement

JICA Guidelines require that “people who must be resettled involuntarily and people whose means of
livelihood will be hindered or lost must be sufficiently compensated and supported by project proponents
etc. in a timely manner.” Further, it notes that “[h]ost countries must make efforts to enable people
affected by projects and to improve their standard of living, income opportunities, and production levels,
or at least to restore these to pre-project levels” 33 (emphasis added). International best practice and
Myanmar law 34 similarly require that affected villagers are not left in a worsened socioeconomic position

difficult because the three households were “grazers”. (JICA Report at p69)
28
Mike Griffiths, Using Vulnerability mapping to measure medium term impact of relocation and resettlement by Special
Economic Zones (SEZ): Thilawa SEZ, Yangon Region, Myanmar, Feb. 2018, pg. 2, available at
http://www.mekongwatch.org/PDF/Thilawa_Vulnerability_Research_Feb2018.pdf.
29
See JICA Guidelines Appendix 1(1). World Bank and Asian Development Bank guidelines on involuntary resettlement
also mandate that project proponents avoid involuntary resettlement is avoided where possible. See United Nations, Basic
Principles And Guidelines On Development based Evictions And Displacement, available at
https://www.ohchr.org/Documents/Issues/Housing/Guidelines_en.pdf; World Bank (WB) Safeguard Policy, OP 4.12, Annex
A, ¶2(a); Asian Development Bank (ADB) Safeguard Policy Statement (SPS) Appendix 2, Safeguards Requirement 2:
Involuntary Resettlement ¶3.
30
See JiICA Guidelines Appendix 1 (3) and (4). See also United Nations, Basic Principles And Guidelines On Development
based Evictions And Displacement, ¶56(I) (“The entire resettlement process should be carried out with full participation by
and with affected persons, groups and communities. States should, in particular, take into account all alternative plans
proposed by the affected persons, groups and communities.”)
31
See JICA Guidelines Appendix 1 (2). See also World Bank Safeguard Policy, OP 4.12, Annex A, ¶2(c) (“Displaced
persons should be assisted in their efforts to improve their livelihoods and standards of living or at least to restore them, in
real terms, to pre-displacement levels or to levels prevailing prior to the beginning of project implementation, whichever is
higher.”); ADB, SPS Appendix 2, Safeguard Requirement 2, ¶ A(1); International Finance Corporation (IFC), Performance
Standard 2, ¶ 2.
32
JICA Guidelines 2.6 (3).
33
Id.
34
The Myanmar 2014 SEZ Law requires the developer or investor to “relocate the persons so as not to lower their original
standard of living” and “fulfill their fundamental needs,” bearing all expenses involved in this process. See SEZ Law §

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after resettlement.

Contrary to JICA Guidelines, Myanmar law, and international best practice, the Project Proponent and the
Myanmar Government have failed to ensure that displaced people’s standards of living are maintained. It
is clear from the current situation of resettled villagers that they are worse off socially and economically
after resettlement. In early 2018, a detailed social impacts report (Annexure 2 attached) was conducted
and compared vulnerability levels of relocated households with non-relocated ones, and found that
relocated households had “significantly higher rates of vulnerability related to economic dependency, debt
and lack of livelihood/income diversity.” 35 The study, which was shared with JICA in early 2018, found
that “relocated households not only have lower levels of income, but are more likely to have expenditure
in excess of annual income, and higher rates of debt and debt interest repayment rates.” 36 It also noted
that “[d]ue to a greater reliance on food purchases, and income insufficiency, relocated households
reported higher rates of food insecurity, and nearly one-third reported taking loans to meet food shortages
in the past year.” 37 These findings, which were completed five years after the first group of villagers
relocated due to the Thilawa SEZ, clearly provide quantitative and qualitative evidence that demonstrates
that villagers are far from being restored to their original conditions.

In the context of livelihood restoration for “the port sub-project (Thilawa Area Phase I),” the
representatives of the TSDG state that JICA’s justification for its failure to undertake monitoring of
livelihood restoration, namely that it was “difficult” to do so because some people from project affected
households moved after receiving their compensation, 38 is poor. While it is true that some people from
project affected households have moved, it would be very easy for the project proponent to establish
where affected persons have moved to if they made genuine attempts to do so, as friends and family in
TSEZ area all aware of where others have moved to. 39

The income restoration program provided to villagers has been largely unsuccessful in assisting their
transition from land-based livelihoods to alternative ones. Villagers from both Zone A and B have reported
that the vocational activities were not useful in finding employment. 40 Despite the developer’s promise

80(a)-(b); EIA Procedure §102, Annex 3, No. 12. Similarly, the EIA Procedure assigns “full legal and financial responsibility
for Project Affected People (PAPs) until they have achieved socio-economic stability at a level not lower than that in effect
prior to the commencement of the Project” to the Project Proponent(s). See EIA Procedure §102. If the Proponent(s) fails to
restore relocated villagers to their original social conditions after resettlement, it can be penalized through a monetary fine
and/or suspension of the EMP approval. See EIA Procedure, Annex 3, No. 12.
35
Mike Griffiths, Using Vulnerability mapping to measure medium term impact of relocation and resettlement by Special
Economic Zones (SEZ): Thilawa SEZ, Yangon Region, Myanmar, Feb. 2018, pg. 2, available at
http://www.mekongwatch.org/PDF/Thilawa_Vulnerability_Research_Feb2018.pdf.
36
Id.
37
Id.
38
JICA Review Report, page 49.
39
Comments from TSDG in a meeting with EarthRights on Tuesday, 5 November 2019.
40
At an interview with EarthRights staff on July 26, 2019, villagers resettled from Zone B as well as community leaders,
who are members of the Thilawa Social Development Group (TSDG) stated that vocational training activities has not been
effective in helping resettled villagers get a job. A TSDG member stated that the message given to villagers was that it is
easy to get a job at the SEZ, but this has not been the case. He discussed his son as an example, noting that he was unable to
get a job at the TSEZ for three years despite having all application documents in order. He also noted that many jobs have

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that villagers will have access to abundant jobs at the SEZ, very few villagers have been able to get these
jobs because of qualification barriers.41 Due to increased expenses and lack of ability to find income,
countless resettled villagers have been forced to borrow from high- risk lenders using their new homes as
collateral, many of them eventually losing their homes. 42 Where JICA states in the Review Report that,
in the context of the port sub-project, it did not promote job opportunities because “affected persons did
not ask for this after their compensation was paid”, TSDG representatives state that this is not true as
many community members applied for jobs but were not offered positions because the training that they
received did not match the qualification requirements of the jobs that were on offer. 43

Despite clear indications that affected villagers from Zone A have not been restored to previous income
levels, TSMC considers them to be fully restored and no longer needing income restoration support, 44 and
JICA has failed to take action to hold the Project Proponent accountable. While income restoration
activities are still underway for resettled Zone B villagers, they are offered largely the same activities as
those offered to Zone A villagers, 45 and their income restoration status so far seems to be following a
similar trajectory. 46 It is clear from the current situation of relocated villagers that the Project Proponent
and the Myanmar Government have breached their obligation under JICA Guidelines, international best
practice, and Myanmar law to ensure that resettled villagers are restored to their original conditions,
failing to take full legal and financial responsibility for them.

Additionally, villagers have suffered various deprivations after resettlement, due to improperly
constructed wells, latrines, and waste management facilities. 47 While physical conditions of the

qualification barriers which most villagers cannot meet. Resettled villagers from Zone B stated that vocational training
activities, such as driving, had been offered to them, but there was low interest and not many villagers participated. They
noted that even the villagers who did participate did not get a job at the SEZ.
41
See id.
42
In 2014, Physicians for Human Rights (PHR) published a report on the conditions of resettled villagers from Zone A,
noting that several households told PHR that they put their homes up for collateral. Physicians for Human Rights (PHR), A
Foreseeable Disaster in Burma: Forced Displacement In the Thilawa Special Economic Zone, November 2014, pg. 14.
November 2014, pg. 16, available at http://physiciansforhu- manrights.org/library/reports/a- foreseeable-disaster-in-
burma.html. Also, in the interview on July 26, 2019 with three resettled villagers from Zone B, the interviewees noted that
out of the 95 households in his resettlement village, there are only 36 households remaining. They stated that the rest had lost
their homes due to being unable to pay their high-interest loans.
43
JICA Review Report, at page 79 and page 205.
44
The third Social Economic Survey report released by the TSMC, which compiled information on the income restoration
status of resettled villagers from Zone A, stated that resettled villagers’ conditions were largely “stabilized” and many of
them had found income sources. After this report, no further monitoring reports were published, and the website states that
the initial vocational training program has been concluded as of June 2014. In the periodic newsletters published by the
TSMC on vocational activities, no activities for resettled villagers from Zone A are included. TWA, “3rd Socio-Economic
Survey (SES) on the Resettlement and Income Restoration Program for Development of Thilawa Special Economic Zone
(Phase 1 Area), available at
http://irp.myanmarthilawa.gov.mm/sites/default/files/3rd%20SES%20%28English%20Version%29.pdf.
45
The RWP for Area 2-2 of Zone B states that “similar vocational training options can be offered to the PAHs of Area 2-2
East after discussions with PAHs.” Essentially, the same activities have been offered to resettled villagers from Zone B,
which consists of mainly driving and sewing training. See RWP, Area 2-2, pg. 42. Like resettled villagers from Zone A, Zone
B villagers complained during the interviews in July 2019 that they were unable to get jobs at the SEZ and had no viable
source of income.
46
The aforementioned PHR report found that residents have been relocated on a plot less than half an acre. See id.
47
For more information, see supra “II. Background” of this report; See also PHR, A Foreseeable Disaster in Burma: Forced
Displacement In the Thilawa Special Economic Zone.

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resettlement site have been improved since then, employment remains a pivotal element of resettled
villagers’ fundamental needs, and this need continues to be unmet. Furthermore, it is alarming that
compensations promised to some villagers during the pre-relocation consultations, including the
vulnerability stipend, have been allegedly unpaid, despite villagers sending multiple letters to the TSMC
and MJTD. 48

ii. The Resettlement Work Plans and EIAs for Zone A and B both did not adequately explore
alternatives for displacement

JICA Guidelines and International best practice requires project proponents to fully explore alternatives
to involuntary displacement, avoiding it where possible. 49 The analysis of alternatives should include not
only alternatives to proposed project area, but also technology, design and operation. 50

In both Zone A and B, Project Proponents did not properly explore alternatives to displacement. The EIA
for Zone A and B both stated that alternative areas were considered for the project, 51 but failed to mention
any alternatives for project design, technology, or operation. Further, the alternative project area analyses
presented in the EIAs were inadequate. For example, the EIA for Zone A stated that alternative areas were
considered but failed to mention where these areas were. 52 Also, it failed to compare the selected project
design with the “without project” situation, contrary to international best practice. 53

While Zone B’s EIA contained a more thorough analysis, including a comparison with the “no project”
scenario, 54 it nonetheless failed to consider other ways of decreasing or avoiding involuntary displacement
besides choosing alternative project areas. Also, the “no project” scenario analysis was riddled with
unsubstantiated assumptions – the EIA concluded that it would be better to have the project in the proposed
area rather than not because without the project, there will be disorderly development in the area, jobs
would not increase, and economic development would be overall limited. 55 There were no figures to

48
At the July 2019 interview with resettled villagers from Zone B, one interviewee mentioned that he was promised a
compensation package of 120,000 lakh total but have not received yet, despite having moved in 2017. He stated that he sent
several letters to the TSMC and MJTD but have not received a reply.
49
See supra note 22.
50
The notion that analysis of alternatives to involuntary resettlement must involve more than just a consideration of
alternative project areas is grounded in international best practice. For example, ADB’s sourcebook states that “Project
design can reduce involuntary resettlement impacts in varied ways. Technical design elements such as alignments for roads,
railways, power lines, canals, and embankments can be carefully altered to minimize their effects on heavily populated areas
or agricultural lands. Rights of way can sometimes be narrowed. Infrastructure or borrow pits can be located on land of low
value. Water and sewerage pipes can be run along existing road corridors. The dam height for reservoir projects might be
lowered to reduce the inundation area while still providing reasonable storage. Buffer walls might be utilized to minimize
noise or other environmental effects which might otherwise have led to relocation.” ADB, Involuntary Resettlement
Safeguards A Planning and Implementation Good Practice Sourcebook – Draft Working Document, ¶66,
https://www.adb.org/sites/default/files/institutional-document/32827/files/ir-good-practices-sourcebook-draft.pdf.
51
See Zone A EIA, Section 3.2; See Zone B EIA, Section 3.3.
52
See Zone A EIA, Section 3.2.
53
See id.
54
See Zone B EIA, Section 3.3.
55
See id.

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substantiate these projections, and the EIA failed to contemplate alternative development projects that
could stimulate economic growth without involuntary displacement.

Alarmingly, most Resettlement Work Plans (RWPs) for Zone A and B drafted by the YRG failed to
mention the consideration of any alternatives. While the RWP for Area 2-2 mentioned alternatives, it
simply referred to the analysis already done in the EIA for Zone B without adding anything new. 56

Considering alternative project areas is only one piece of the puzzle for exploring alternatives to
displacement. Due to the inadequate analysis contained in the RWPs and EIAs, the Project Proponent
have failed to comply with international best practice and JICA Guidelines, and JICA has failed to hold
it accountable.

iii. Affected villagers from Zone A and B did not have meaningful opportunities to participate in
their resettlement processes

Contrary to international best practice and JICA Guidelines, 57 resettled villagers from both zones were
not given meaningful opportunities to participate in their relocation processes. For one, they received a
letter in 2013 demanding them to relocate in 14 days or spend 30 days in jail, before any consultation
took place. The Project Proponent did not deem villagers’ opinions as important in the resettlement
process at all, attempting to unilaterally force them to vacate their homes.

While four consultations for Phase I of the Thilawa SEZ were arranged after villagers and CSOs objected,
these consultations were plagued by lack of transparency and coercion. As explained earlier in this report,
villagers reported that they were pressured by authorities to sign compensation agreements, given
agreements that they did not understand, and were not allowed to retain copies of it after signing. Also,
they stated that they were not given clear information about compensation amounts, and that
compensation amounts sometimes differed among villagers. 58

While some improvements were made for the consultation process of Zone B, with more detailed meeting
notes and comments from villagers documented in the RWPs, it also failed to comply with international
best practice. First, there have been allegations that community leaders have been barred from attending
consultations since 2016. 59 Hence, it is possible that the consultations were not truly open forums for all
villagers to participate and voice their opinions. Furthermore, while villagers noted that they were able to
voice their concerns during consultations, they shared that they are now frustrated because they had been

56
Yangon Regional Government (YRG), Resettlement Work Plan for Area 2-2, pg. 36.
57
See supra note 23.
58
For example, during the aforementioned July 2019 interview with resettled villagers from Zone B, one interviewee stated
that those that had good relations with authorities got better compensation and that his compensation was calculated
incorrectly, but he had no choice but to accept the incorrect, lesser amount.
59
EarthRights International, Interview with three TSDG members, July 26, 2019.

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given misleading information at these meetings. 60 They have reported that many of the promises made
during the consultations had not been fulfilled more than a year after relocation. 61 The lack of follow-up
on commitments made at the resettlement consultations signifies that villagers did not have a meaningful
opportunity to participate in their resettlement process. Without accurate information, their participation
could not have been meaningful, as the feedback they gave at these meetings were based on the
information presented by the developers.

Additionally, for both zones, many villagers did not have a proper opportunity comment on their RWP.
Zone A’s RWP simply stated that the workplan is planned to be disclosed to the public, without stating
how long it will be disclosed, where it will be disclosed, and whether villagers will be able to comment. 62
Given this lack of details, villagers were likely unable to comment meaningfully on their RWP at all.
Furthermore, while the RWPs for Zone B (Area 2-1, 2-2, 2-1 expanded) were disclosed for villagers to
comment, there was a wide discrepancy in disclosure times, ranging from 40 days to 2 weeks. 63 Two
weeks is not enough time to comment on a RWP, and hence several affected villagers did not have a
meaningful opportunity to participate in the RWP drafting process.

Currently, the consultation process for the resettlement of villagers from Area 2-2 West of Zone B is
underway. Despite the fact that nearly half the villagers from that area are Tamil speakers, all consultations
and resettlement documents have been done in Burmese. Effectively, about half of the affected population
has been barred from public participation in the resettlement process. Even the most basic resettlement-
related information, such as the RWP, have not been presented in a manner that is understandable to a
significant proportion of villagers. 64 Therefore, the consultation process for Area 2-2 West, too, do not
seem to comply with international standards and JICA Guidelines on meaningful engagement and
consultations. 65

Lastly, in a recent interview with TSDG members, community leaders reported that villagers were being
threatened against cooperating with NGO by MJTD and the government authorities. 66 This is a highly
troubling development that flies directly in the face of encouraging affected villagers to share their
opinions and advocate for their preferences.

To adhere to the guidelines on meaningful stakeholder participation in involuntary resettlement processes,


JICA must hold the Project Proponent accountable and ensure that villagers are able to contribute

60
EarthRights International, Interview with resettled villagers from Zone B, July 26, 2019.
61
Id.
62
See Yangon Regional Government, “Resettlement Work Plan (RWP) for Development of Phase 1 Area Thilawa Special
Economic Zone (SEZ),” Nov. 2013, pg. 38.
63
The RWP disclosure period for Area 2-1 was 40 days, while the same for Area 3-1 was 2 weeks.
64
The RWP for Area 2-2 West has been released only in English and Burmese.
65
International guidelines on resettlement require that information is presented to PAPs in a language that is understandable.
See e.g. ADB, SPS Appendix 2, Safeguard Requirement 2, ¶15.
66
Earth Rights International, Interview with TSDG Members, July 26, 2019.

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meaningfully to decision-making concerning their own resettlement.

Altogether, many of relocated villagers’ fundamental needs remain unmet, and JICA must urge the Project
Proponent and Myanmar Government to fulfill its responsibilities under its Guidelines on involuntary
resettlement.

iv. Breach of JICA GLs on the establishment of a Grievance Mechanism

Section 7.3 of “Appendix 1: Environmental and Social Considerations Required for Intended Projects” of
the JICA GLs states that “appropriate and accessible grievance mechanisms must be established for
affected people and their communities” in cases of involuntary resettlement.

JICA states in its Review Report that grievance mechanisms have been established in 43 of 44 Category
A and Category B Projects, including Thilawa. No further information on the nature of the Thilawa
grievance mechanism is provided. The report fails to acknowledge that even though community members
were first relocated in Thilawa in 2013, no grievance mechanism was established in TSEZ until 2017.
JICA and its project proponents were therefore operating in breach of GL Appendix Section 7.3 for a
period of four years. Community members first sought to develop a grievance mechanism since in late
2014 and early 2015. In 2015, stakeholders discussed an interim mechanism, but all backed out when the
community members tried to use it. So not only did the project proponent fail to have a grievance
mechanism in place, but they actively rejected efforts to create one.

As JICA and the project proponents know, the failure of JICA and the project proponents to adhere to
international standards and to the JICA GLs and establish an accessible and appropriate grievance
mechanism for such an extended period led community members in Thilawa to establish a Design
Committee who together with the TSDG began to develop a Community Driven Operational Grievance
Mechanism (CD-OGM) in consultation with the broader population. The Design Committee shared a
briefer and proposal for the CD-OGM with JICA and the project proponent in 2016 and the CD-OGM has
since been discussed extensively with stakeholders from JICA, the Thilawa SEZ Management Committee
(TSMC), and Myanmar Japan Thilawa Development Limited (MJDT). However, subsequent to this
process, in November 2017, the TCMC and MJDT elected to launch an entirely separate grievance
mechanism, the Thilawa Complaints Management Procedure (TCMP), without consulting with the
Design Committee or affected community members.

The development of the TCMP therefore appears to have actively declined to meet a core requirement of
the United Nations Guiding Principles on Business and Human Rights (UNGPs), namely that a grievance
mechanism should be “based on engagement and dialogue”. Beyond this, the Design Committee, the
TSDG and EarthRights have a number of concerns about the TCMP as it its development and its procedure
fall short of international standards in numerous ways, as detailed in EarthRights’ analysis of the TCMP
(Annexure 3 attached). EarthRights sent this analysis to JICA’s offices in Myanmar and in Japan in

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February 2018 yet the issues that it raises are not reflected in the Review Report.

This a significant failing of the JICA Review Report. JICA GLs should be strengthened to include detailed
substantive criteria to assess whether the development and substance of grievance mechanisms aligns
with the UNGPs and other international standards.

In a meeting with EarthRights in November 2019, one community member stated that a complaint that he
had lodged through the TCMP has gone unresolved for a full year.

In 2019, because the stakeholders refused to make improvements to the TCMP based on feedback received,
EarthRights sought an external expert to review both the TCMP and the CD-OGM. EarthRights and/or
other stakeholders may elect to submit supplementary comments based on this review.

d) Concerns regarding the implementation of the objection procedure

JICA acknowledges in its report that a formal objection to the “Thilawa Class A Project” was raised in
2014 and that it proceeded to the investigation by JICA Examiners. JICA states that non- compliance with
its guidelines was not confirmed, but that the examiners advised JICA and the project proponents to work
to find a solution to the issues raised in the objection. 67 As demonstrated by the discussion above, many
of the issues raised in the objection (such as loss of livelihood opportunities and a failure to incorporate
community voices into decision making, among others) remain largely unresolved. One of the outcomes
that followed the objection procedure was that the MJTD verbally offered three acres of common land to
affected persons for the purposes of growing vegetables for home use, however a land dispute with the
original owner of the land in question prevented affected persons from commencing activities on this land.
This issue was raised by affected persons at an annual meeting with JICA earlier this year and JICA stated
that it would revert back to affected persons, however it has not yet done so. 68

JICA does not suggest any need to review its freestanding objection procedures in the Review Report. We
submit that JICA should take this review opportunity to assess the objection procedures at the same time
as the JICA GLs, since the objection procedures provide an important mechanism for communities to assert
their rights. At the time of making this submission, we have not had the opportunity to consult with affected
persons in the TSEZ regarding the nature of amendments to be made to the objection procedures based
on their experience of the objection process. Should affected persons wish to make submissions,
supplementary comments will be submitted on this issue at a later stage.

Concluding statements

67
JICA Report, page 205.
68
EarthRights meeting with TSDG members on Tuesday, 5 November 2019.

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While we recognise that it would not be practical for the JICA Review Report to canvas all 100 of its review
projects in this level of detail, we submit that the inaccurate and incomplete manner in which the effects
of the TSEZ projects have been reviewed is problematic. The fact that the report does not paint an accurate
picture of the impacts of the TSEZ projects has the effect that it fails to accurately assess the efficacy of
the JICA Guidelines. This defeats the purpose of this review as a whole. Selective reporting on the
implementation of the Guidelines means that key gaps in the guidelines will be obfuscated, and
opportunities to strengthen the Guidelines to better align with their overall purpose will be missed.

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