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Document of The World Bank
FOR OFFICIAL USE ONLY
Report No: 82640-BD
INTERNATIONAL DEVELOPMENT ASSOCIATION
PROJECT APPRAISAL DOCUMENT
ON A
PROPOSED CREDIT IN THE AMOUNT OF SDR 266.6 MILLION
(US$410.00 MILLION EQUIVALENT)
TO THE
PEOPLE’S REPUBLIC OF BANGLADESH
FOR A
MUNICIPAL GOVERNANCE AND SERVICES PROJECT
November 26, 2013
Sustainable Development Department Urban and Water Unit South Asia Region
This document is being made publicly available prior to Board consideration. This does not imply a presumed outcome. This document may be updated following Board consideration and the updated document will be made publicly available in accordance with the Bank’s Policy on Access to Information.
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CURRENCY EQUIVALENTS (Exchange Rate Effective October 31, 2013)
Currency Unit = Bangladesh Taka (BDT) US$1.00 = BDT79.00 BDT1.00 = US$0.013 US$1.00 = SDR0.65018
FISCAL YEAR July 1 – June 30
ABBREVIATIONS AND ACRONYMS
ADP
Annual Development Program
BMDF Bangladesh Municipal Development Fund CAS Country Assistance Strategy DPP Development Project Proposal EA Environmental Assessment EMP Environmental Management Plan ESMF Environment and Social Management Framework GoB Government of Bangladesh IDA International Development Association LGD Local Government Division (of the Ministry of Local Government, Rural
Development and Cooperatives) LGED Local Government Engineering Department M&E Monitoring and Evaluation MoF Ministry of Finance MTR Mid-term Review NCB National Competitive Bidding O&M Operations and Maintenance PDO PIM
Project Development Objective Project Implementation Manual
PMU Project Management Unit PSC Project Steering Committee RAP Resettlement Action Plan SA Social Assessment TLCC Town Level Coordination Committee ULB Urban Local Bodies WLCC Ward Level Coordination Committee
Regional Vice President: Philippe H. Le Houerou
Country Director: Johannes Zutt Sector Director: John Henry Stein Sector Manager: Ming Zhang
Task Team Leader: Shenhua Wang/Zahed Khan
3
TABLE OF CONTENTS
I. STRATEGIC CONTEXT .........................................................................................................1
A. Country Context ............................................................................................................. 1
B. Sectoral and Institutional Context ................................................................................. 1
C. Higher Level Objectives to which the Project Contributes .......................................... 3
II. PROJECT DEVELOPMENT OBJECTIVE .........................................................................3
A. PDO ................................................................................................................................ 3
B. Project Beneficiaries ...................................................................................................... 3
C. PDO Level Results Indicators ........................................................................................ 3
III. PROJECT DESCRIPTION ...................................................................................................4
A. Project Components ...................................................................................................... 4
B. Project Cost and Financing ............................................................................................ 5
C. Lessons Learned and Reflected in the Project Design ................................................... 5
IV. IMPLEMENTATION .............................................................................................................6
A. Institutional and Implementation Arrangements ............................................................ 6
B. Results Monitoring and Evaluation ................................................................................ 7
C. Sustainability .................................................................................................................. 7
V. KEY RISKS AND MITIGATION MEASURES ...................................................................8
A. Risk Ratings Summary Table ........................................................................................ 8
B. Overall Risk Rating Explanation .................................................................................... 8
VI. APPRAISAL SUMMARY ......................................................................................................9
A. Economic and Financial Analysis .................................................................................. 9
B. Technical ...................................................................................................................... 10
C. Financial Management ................................................................................................. 11
D. Procurement ................................................................................................................. 11
E. Social ............................................................................................................................ 12
F. Environment ................................................................................................................. 13
G. GAAP and Third Party Monitoring ............................................................................. 14
Annex 1: Results Framework and Monitoring .........................................................................15
Annex 2: Detailed Project Description .......................................................................................17
4
Annex 3: Implementation Arrangements ..................................................................................30
Annex 4: Operational Risk Assessment Framework (ORAF) .................................................45
Annex 5: Implementation Support Plan ....................................................................................49
Annex 6. Governance and Accountability Action Plan (GAAP) .............................................52
5
PAD DATA SHEET
Bangladesh
Municipal Governance and Services Project
PROJECT APPRAISAL DOCUMENT
.
SOUTH ASIA
SASDU
Report No.: PAD543
.
Basic Information
Project ID Lending Instrument EA Category Team Leader
P133653 Specific Investment Loan
B - Partial Assessment Shenhua Wang/Zahed Khan
Project Implementation Start Date Project Implementation End Date
23-Dec-2013 30-June-2020
Expected Effectiveness Date Expected Closing Date
23-April-2014 30-June-2020
Joint IFC
No
Sector Manager Sector Director Country Director Regional Vice President
Ming Zhang John Henry Stein Johannes Zutt Philippe H. Le Houerou
.
Borrower: Government of Bangladesh
Responsible Agency 1: Local Government Engineering Department
Contact: Iftekhar Ahmed Title: Superintending Engineer (Planning)
Telephone No.:
880-2-9127158
Email: [email protected]
Responsible Agency 2: Bangladesh Municipal Development Fund
Contact: K. M. Nurul Huda Title: Managing Director
Telephone No.:
(880-2) 805 8485
Email: [email protected]
6
.
Project Financing Data(in USD Million)
[ ] Loan [ ] Grant [ ] Other
[ X] Credit [ ] Guarantee
Total Project Cost: 471.7648 Total Bank Financing: 410.00
Total Cofinancing: 61.76 Financing Gap: 0.00
.
Financing Source Amount
BORROWER/RECIPIENT 61.76
IDA (new) 207.89
IDA (recommitted) 202.11
Total 471.76
.
Expected Disbursements (in USD Million)
Fiscal Year FY14 FY 15 FY 16 FY 17 FY 18 FY 19 FY 20
Annual 0.00 4.00 26.00 60.00 90.00 130.00 100.00
Cumulative 0.00 4.00 30.00 90.00 180.00 310.00 410.00
.
Institutional Data
Sector Board
Urban Development
.
Sectors / Climate Change
Sector (Maximum 5 and total % must equal 100)
Major Sector Sector % Adaptation Co-Benefits %
Mitigation Co-Benefits %
Public Administration, Law, and Justice
Sub-national government administration
20
Public Administration, Law, and Justice
Public administration- Other social services
15
Transportation General transportation sector
20
Water, sanitation and flood protection Solid waste management 10
Water, sanitation and flood protection General water, sanitation and flood protection sector
35
7
Total 100
I certify that there is no Adaptation and Mitigation Climate Change Co-benefits information applicable to this project.
.
Themes
Theme (Maximum 5 and total % must equal 100)
Major theme Theme %
Public sector governance Administrative and civil service reform 5
Public sector governance Decentralization 5
Public sector governance Public expenditure, financial management and procurement
5
Social dev/gender/inclusion Participation and civic engagement 5
Urban development Municipal finance 20
Urban development Municipal governance and institution building
30
Urban development Other urban development 20
Urban development Urban planning and housing policy 10
Total 100
.
Project Development Objective(s)
Proposed Development Objective(s)
The project development objective is to improve municipal governance and basic urban services in participating Urban Local Bodies (ULBs), and to improve Recipient’s capacity to respond promptly and effectively to an Eligible Crisis or Emergency.
.
Components
Component Name Cost (USD Millions)
Component 1. Municipal Governance and Basic Urban Services Improvement
Total Cost: 246.35 IDA: 204.00
Component 2. BMDF Demand-based Financing for Urban Services
Total Cost: 171.50 IDA: 155.00
Component 3. Capacity Building and Implementation Support
Total Cost: 53.91 IDA: 51.00
Component 4. Contingent Emergency Response Total Cost: 0.00
.
Compliance
8
Policy
Does the project depart from the CAS in content or in other significant respects?
Yes [ ] No [ x ]
.
Does the project require any waivers of Bank policies? Yes [ ] No [ x ]
Have these been approved by Bank management? Yes [ ] No [ ]
Is approval for any policy waiver sought from the Board? Yes [ ] No [ x ]
Does the project meet the Regional criteria for readiness for implementation?
Yes [ x ] No [ ]
.
Safeguard Policies Triggered by the Project Yes No
Environmental Assessment OP/BP 4.01 X
Natural Habitats OP/BP 4.04 X
Forests OP/BP 4.36 X
Pest Management OP 4.09 X
Physical Cultural Resources OP/BP 4.11 X
Indigenous Peoples OP/BP 4.10 X
Involuntary Resettlement OP/BP 4.12 X
Safety of Dams OP/BP 4.37 X
Projects on International Waterways OP/BP 7.50 X
Projects in Disputed Areas OP/BP 7.60 X
.
Legal Covenants
Name Recurrent Due Date Frequency
Implementation Covenants
(a) The Recipient shall cause BMDF, by no later than December 31, 2016, (i) to develop and adopt a business plan for sustainable long-term financing operations, in form and substance satisfactory to the Association, including achieving 100% recovery of BMDF’s operating costs from its own revenues by December 31, 2019; and (ii) thereafter implement such plan in a manner satisfactory to the Association.
(b) The Recipient shall, by the earlier of May 1, 2014 and the date on which the Recipient proposed to select the first Sub-Project, adopt a Project Implementation Manual in form and substance satisfactory to the Association.
Team Composition
Bank Staff
9
Name Title Specialization Unit
Shenhua Wang Senior Urban Specialist Team Lead/Urban Development SASDU
Zahed H. Khan Senior Urban Spec. Co-Team Lead/Institutional and Implementation
SASDU
Abdu Muwonge Senior Economist Municipal Finance/Governance SASDU
Da Zhu Senior Economist Municipal Development Fund/ Economic Analysis
SASDU
Christopher T. Pablo Senior Urban Development Specialist
Urban Development SASDU
Shakil Ahmed Ferdausi
Senior Environmental Specialist
Environmental SASDI
Junxue Chu Senior Finance Officer Financial Management/Disbursement
CTRLN
Hisham Kahin Lead Counsel Legal LEGES
Matthew Moorhead Associate Counsel Legal LEGES
Burhanuddin Ahmed Senior Financial Management Specialist
Financial Management/Disbursement
SARFM
Tanvir Hossain Senior Procurement Specialist
Procurement SARPS
Md. Akhtaruzzaman Social Development Specialist
Social Safeguards SASDS
Iqbal Ahmed Environmental Specialist Environmental SASDI
Farhana Tarannum Ahmad
Operations Officer Operations SACBD
Chyi-Yun Huang Young Professional Urban Development SASDU
Mark Ellery Water & Sanitation Specialist
Water & Sanitation TWISA
M. Akram-ul Aziz Consultant Implementation Arrangement SASDU
Olasumbo S. Adeyemo Program Assistant Program Assistance SASDO
Amani Haque Program Assistant Program Assistance SASDO
Danqing Zhu Consultant M&E SASDU
Non Bank Staff
Name Title Office Phone City
Jamie Boex Sr. Public Finance Expert/Consultant
Public Finance Washington DC
Christoph Hugi Senior Finance Specialist/Consultant
Financial Analysis Switzerland
10
Marie Brechbuehler Senior Economist/Consultant
Economic Analysis Switzerland
Chandra Godavitarne Municipal Engineer/Consultant
Engineering Washington DC
Locations
Country First Administrative Division
Location Planned Actual Comments
Bangladesh Urban Local Bodies, e.g., municipalities
Throughout the country
Approx. 26 pre-selectedULBs,
and other ULBs
based on demand.
26 ULBs under Component 1, and other qualified ULBs with demand-based funding support under Component 2.
1
I. STRATEGIC CONTEXT
A. Country Context
1. With about 150 million people occupying a landmass of around 150,000 km2, Bangladesh is one of the most populous, as well as one of the most densely populated countries in the world. According to the 2011 census, the total population density is about 1,015 people per km2 and the urban population density is about 1,900 people per km2. The population density in Bangladesh is the highest in the world, excluding city-states and small islands, and is three times higher than that of India. 2. Since the 1980s, Bangladesh has witnessed sustained urbanization fueled by strong economic growth. While Bangladesh remains a low-income country, it had a steady per capita gross national income (GNI) growth at a compound annual growth rate of 4.9 percent per year over the last three decades. Its economic growth was also accompanied by structural transformation. The contribution of agriculture to GDP fell from 30% in 1990 to 20% in 2010, while the contribution of the urban sector to GDP increased from 37% to an estimated 60% over the same period.
3. Despite remarkable progress in reducing poverty during the past two decades, Bangladesh remains the poorest country in South Asia. Using the international poverty line of PPP$1.25 per person per day, the proportion of the country’s population living in poverty was around 43 percent in 2010. Poverty in urban areas is less pervasive and extreme than in rural areas. Looking ahead continued employment growth and more rapid urbanization will be key to sustaining Bangladesh’s rapid pace of poverty reduction. 4. Bangladesh is rapidly urbanizing and great pressure is exerted on basic urban services, particularly in district towns and municipalities (pourashavas). Over the last 40 years, Bangladesh experienced some of the most rapid urbanization in South Asia. The urban share of population rose from 15% in 1980 to 28% in 2010. Bangladesh’s cities are characterized by poor infrastructure and low levels of urban services. For example: (i) road space is inadequate, roads are not well maintained, and traffic congestion has worsened; (ii) drainage systems are not well planned, the few existing drains are not cleaned regularly and do not function satisfactorily; (iii) water supply is inadequate and unsafe; (iv) solid waste management practices are weak; and (v) pollution levels of water, air, soil, and noise have increased. These inadequacies constrain Bangladesh’s competitiveness, and affect its productivity, connectivity and livability. B. Sectoral and Institutional Context
5. Urban local bodies (ULBs) face constraints to function as strong, responsive and inclusive local government institutions despite the progress made on the decentralization reform agenda. Bangladesh has 331 Urban Local Bodies (ULBs), comprising 10 city corporations, and 321 municipalities (or pourashavas).Under the decentralization reform agenda, Government of Bangladesh (GoB) introduced legislative reforms in local governance in the years up to and during 2008-2009, including enacting the new Pourashava Law and a City Corporation Law. Despite progress in the decentralization reform agenda, the quality of urban
2
institutions is still weak; they have limited fiscal autonomy and decision making powers, inadequate own source revenues, and weak systems of accountability. 6. ULBs lack adequate own source revenues to finance new investments or operations and maintenance (O&M). Current sources of revenue for ULBs are: (i) central government fiscal transfers – the GoB Annual Development Program (ADP); and (ii) own source revenues, e.g., holding tax, conservancy tax and water charges. Own source revenues of ULBs are small, and are in the range of 4% to 6% of total annual expenditures. Collection performance for the major source of revenue, the holding tax, ranges around 30% to 40%. ULBs will continue to depend on the ADP transfers from GoB to meet investment and recurrent expenditures for the foreseeable future. However, ADP transfers are not adequate to finance new infrastructure and services such as roads, drains, water treatment plants, solid waste collection and disposal. The commercial banking sector provides no funding to ULBs at present, primarily due to the lack of creditworthiness. Strengthening of finances, management and enhanced transparency in ULBs is necessary to improve creditworthiness. 7. In response to these urban governance challenges, the Sixth Five Year Plan lays out the GoB’s priorities to address service delivery deficiencies and to further reduce urban poverty. The priorities listed include: emphasis on enhancing participation of various urban stakeholder groups in service delivery; providing greater clarity in the roles and responsibilities of ULBs; improving municipal finances; strengthening systems of financial accountability; improving physical and sectoral planning and implementation capacity; improving coordination among various service agencies; and promoting private-public partnerships. The International Development Association (the Association), along with an increasing segment of the global development community, has been working with GoB to identify and implement programs to municipal governance and service delivery challenges by strengthening local ownership while relying on country systems.
8. The AssociationSupport to ULB Development. Since 1999, the Associationhas supported basic urban services development and capacity building of ULBs through the Municipal Services Project (MSP) that closed in June 2012. The MSP comprised: urban services improvements in 17 ULBs in water supply, sanitation, solid waste services, slum upgrading, etc.; and capacity building, including the establishment of the Municipal Support Unit (MSU) in Local Government Engineering Department (LGED); launch of a municipal database; support for the Bangladesh Municipal Development Fund (BMDF) to provide a demand-based credit window for ULBs; and project implementation support. During the 12 year implementation period, the project received three rounds of additional IDA funding, to respond to emergency flood damage rehabilitation works after the major floods in 2004 and 2007, and to scale up BMDF operations. MSP helped to enhance the capacity and effective management of ULBs through support for financing critical basic urban services, improvement of own-source revenue generation, and enhancement of urban planning, procurement and financial management. 9. Local Government Engineering Department. LGED is the main channel for GoB funds for infrastructure investments in ULBs. The portfolio managed by LGED was close to US$1 billion in 2012. LGED has extensive project management capabilities and successfully supported ULBs in the implementation of infrastructure projects in the MSP project period. The
3
Municipal Support Unitestablished in LGED provides comprehensive capacity building for ULBs, including computerization of administrative operations. LGED and the MSU have been widely used by government and other development partners such as the Asian Development Bank. 10. Bangladesh Municipal Development Fund. Established in 2002, BMDF is a state company registered under the Companies Act (1994), which plays an important role in providing an additional window for demand-based funding to ULBs for municipal development projects. It introduced the culture of debt financing for improvement of urban services. In addition to providing financing to ULBs, it has provided technical assistance to ULBs to assume responsibility for most of the implementation activities. BMDF provided financial support amounting to US$103 million to 154 ULBs to finance 595 sub-projects under the MSP. BMDF financed sub-projects were sound, and the loan repayment ratio was 80%, paving the way for its role in nurturing municipal debt financing. BMDF is also working with other potential investors, such as the Islamic Development Bank, to raise funds for urban services. C. Higher Level Objectives to which the Project Contributes
11. The Country Assistance Strategy (CAS) for FY11-14 (Report 54615-BD, September 15, 2010) supports Bangladesh’s growth agenda and emphasizes underpinning it with stronger governance, both at the central and local levels, through addressing persistent governance challenges that undermine the effectiveness of the public sector. The proposed investment operation is fully aligned with the CAS. Specifically, it supports the strategic objective of “increasing transformative investments and enhancing the business environment”, and contributes to the CAS outcomes of “improved planning and management of urbanization” and “increased infrastructure provision, access and efficiency”. As the follow-on project to the MSP, the proposed investment operation aims to address weak governance and municipal management, insufficient planning, under-investment in basic infrastructure services, and operations and maintenance deficiencies. II. PROJECT DEVELOPMENT OBJECTIVE
A. PDO
12. The project development objective (PDO) is to improve municipal governance and basic urban services in participating ULBs, and improve the Recipient’s capacity to respond promptly and effectively to an Eligible Crisis or Emergency.
B. Project Beneficiaries 13. The main project beneficiaries will be about 3.4 million people (of whom 45% will be women) in participating ULBs. Other beneficiaries include staff from implementing agencies, e.g., ULBs, LGED, and BMDF, who will benefit from capacity building activities.
C. PDO Level Results Indicators
4
14. Achievement of the PDO will be measured by: (i) the number of people in urban areas provided with improved urban services (including percentage of women beneficiaries); (ii) the percentage of ULBs (among the 26 LGED-supported ULBs) that achieve targeted improvements in governance, financial management and own-source revenue generation; and (iii) quick availability of funds for emergency response operations (triggered in the case of a major emergency). The Results Framework, including monitoring indicators, is shown in Annex 1. III. PROJECT DESCRIPTION
A. Project Components
15. The project comprises four components briefly described below. A detailed description of the components and project costs is provided in Annex 2.
Component 1 - Municipal Governance and Basic Urban Services Improvement (Total Cost US$246.35 million; IDA US$204 million). 16. This component will provide financial support to 26 pre-selected ULBs with high economic growth and job creation potential, located along the three growth corridors and three district towns in the South. 17. Sub-component 1(a): Provision of Financial Support to pre-selected ULBs for the carrying out of sub-projects aimed at improving the delivery of basic urban services (Total US$204 million: IDA US$184 million; GoB US$20 million) comprising: (i) Base Allocation (IDA US$133 million) to pre-selected ULBs, on an annual basis, based on population and classification of respective ULBs1; and (ii) Performance-based Allocation (IDA US$51 million) to ULBs that demonstrate performance improvements in municipal planning, social accountability, public financial management and revenue mobilization, evaluated against ten performance indicators (details in Annex 2). 18. Sub-component 1(b): Provision of financial support for operations and maintenance (O&M)(Total Cost US$28 million including IDA US$20 million and ULBs US$8 million): financial support for O&M, on a declining basis, over the project period to the 26 pre-selected ULBs for structured routine preventive maintenance of roads, drains, street lights, markets, public toilets, street cleaning and solid waste collection, with ULBs increasing their annual O&M budget allocations proportional to the declining IDA financial support. Component 2: BMDF Demand-based Financing for Urban Services (Total Cost US$171.5 million; IDA US$155 million, ULBs US$ 16.50 million). 19. Provision of demand-based sub-credits by BMDF to eligible ULBs for basic urban services improvement investment costs, at an 80:20 grant to loan ratio.. ULBs will be required to finance 10% of investment costs.
1 Class A are ULBs with revenues over 6 million Taka; Class B are ULBs with revenues between 2.5 million Taka and 6 million and Class C are ULBs with revenues up to 2.5 million.
5
Component 3: Capacity Building and Implementation Support (Total Cost US$53.91 million, including IDA US$51.00 million). 20. Sub-component 3(a): capacity building for ULBs undertaken by LGED, implementation support for LGED, and support for development of a National Municipal Performance Evaluation System and a GIS-based Urban Property and Asset Management System. 21. Sub-component 3(b): capacity building for ULBs supported by BMDF, and long-term road map study and implementation support for BMDF. 22. Sub-component 3(c): support for third party monitoring for the Governance and Accountability Action Plan (GAAP) managed by Local Government Division (LGD). Component 4. Contingent Emergency Response (Total Cost US$0). 23. This component will support, at GoB request, response and reconstruction activities following an adverse natural or man-made event that causes a major disaster, by re-allocating the IDA credit to this component.
B. Project Cost and Financing 24. The total project cost is about US$471.76 million including contingencies. The project will be financed by an IDA Credit of US$410.00 million, with GoB and ULBs providing counterpart funds of US$61.76 million. Summary costs are provided below; more details of project costs are provided in the Appendix to Annex 2.
Project Costs by Component (US$ million)
Component Name Total Cost
IDA GoB ULBs
Component 1: Municipal Governance and Basic Urban Services Improvement
246.35 204.00 34.35 8.00
Component 2: BMDF Demand-based Financing for Urban Services
171.5
155.00 0.00 16.50
Component 3: Capacity Building and Implementation Support
53.91 51.00 2.91 0.00
Component 4: Contingent Emergency Response
0.00 0.00 0.00 0.00
Total 471.76 410.00 37.26
24.50
C. Lessons Learned and Reflected in the Project Design
25. The Implementation Completion and Results (ICR) report of the previous project (MSP) concluded that the project had performed well overall, and had largely achieved its project
6
development objective, except poverty reduction. The performance of the two key implementing agencies (LGED and BMDF) was rated as satisfactory. The ICR also noted that: (i) the project demonstrated the feasibility of a municipal development fund to assist a large number of ULBs, and function as an additional financing window to supplement the ADP transfers of the GOB; (ii) BMDF financing was the only source of demand and credit-based financing available for smaller municipalities; (iii) the project design did not address measures necessary to sustain BMDF operations after MSP; (iv) MSU was an effective resource for capacity building of ULBs; and (v) inclusion of flood emergency rehabilitation for three flood events contributed to a large extent to the exceptionally long project implementation period. 26. Lessons learned and reflected in project design include: (i) provision of incentives to ULBs to enhance improvements in governance, municipal management and operation and maintenance of infrastructure; (ii) strengthening BMDF to expand the demand-driven process to provide financing to ULBs for urban services improvement; (iii) nurturing the culture of borrowing in ULBs to reduce their dependence on GoB as the only financing source in the long-term; (iv) improvement of M&E in project design, and include baseline data and measurable indicators; and (v) continuation of support to MSU to enhance its performance, including more hands–on involvement to operationalize management improvements. IV. IMPLEMENTATION
A. Institutional and Implementation Arrangements
Organizational Arrangements 27. A Project Steering Committee (PSC) will be established in the Local Government Division (LGD), chaired by the Secretary of LGD, including representatives from the Ministry of Finance (MoF), among other agencies, to provide overall guidance and policy directions. 28. Implementing Agencies. The three implementing agencies are: the Local Government Engineering Department (LGED); the Bangladesh Municipal Development Fund (BMDF); and the Local Government Division (LGD). 29. The LGED Project Management Unit (LGED PMU) has been established at the LGED headquarters, and included a Project Director as well as a Project Coordinator and other requisite staff. The PMU is responsible for the management and administration of Component 1, and Sub-component 3(a) of Component 3. Its responsibilities are discussed in Annex 3. 30. BMDF will be responsible for the overall management and implementation of Component 2 and Sub-component 3(b) of Component 3. BMDF will screen the potential borrowers, review and appraise sub-project proposals prepared by ULBs for BMDF financing. BMDF will engage consultants to: develop a strategic road map for future sustainable operations; improve its appraisal procedures and operations; and strengthencapacity of its staff. BMDF will also engage consultants for management and supervision of sub-projects at ULBs as well as support BMDF to reviewing and checking the sub-project proposals, designs, drawings and draft bidding documents of sub-projects.
7
31. Local Government Division (LGD), Ministry of Local Government, Rural Development and Cooperatives. The Monitoring and Evaluation (M&E) Wing of LGD will supervise the implementation of the Third Party Monitoring(Sub-component 3(c) of Component 3 that will be carried out by consultants. 32. Retroactive Financing. The project will provide retroactive financing of up to US$1.0 million for eligible expenditures paid by LGED and BMDF between March 1, 2013 and the date of signing the Financing Agreement, for consultancies, training and workshops.
33. Project Implementation Manual. LGED and BMDF will jointly prepare a Project Implementation Manual, no later than May 1, 2014, containing detailed arrangements and procedures for institutional coordination and day-to-day execution of the project, including project budgeting, disbursement and financial management, environmental and social management, monitoring, evaluation, reporting and communication, eligibility criteria, performance evaluation, and implementation arrangements for sub-projects and financial support for O&M, and relevant provisions for Implementation Partnership Agreements and Sub-credit Agreements, and such other administrative, financial, technical, and organizational arrangements and procedures. B. Results Monitoring and Evaluation
34. Results Framework. Annex 1 provides the detailed Results Framework. Monitoring and evaluation of the overall project and Component 1 will be carried out by LGED. BMDF will be responsible for monitoring and evaluation of Component 2. M&E of Component 3 will be jointly managed by LGED and BMDF. 35. Project Monitoring Arrangements. LGED PMU will prepare six monthly progress reports, in accordance with the format outlined in the Project Implementation Manual. The progress reports will cover: (i) physical and financial progress achieved against agreed implementation and disbursement indicators; (ii) issues and problem areas, including comments on actions to address identified problems; and (iii) work programs and cost estimates for the coming quarter, including revised estimates for the current quarter. Similarly, BMDF will submit six monthly progress reports which will include lending commitment levels, lending portfolio status, loan maturities, non-performing loans, etc. Performance and monitoring indicators will also be required from each ULB borrowing from the BMDF. A mid-term review of the project will be carried out no later than June 2017, to review overall progress and take necessary actions for restructuring the project, if appropriate. C. Sustainability
36. The project addresses the main sustainability issues identified in the MSP ICR, namely: sustained good municipal performance in governance and management; improved operations and maintenance of urban infrastructure; and the sustainability of BMDF. 37. GoB has agreed to the introduction of a performance-based formula for municipal basic services financing for ULBs as well as O&M support on a declining basis. These will provide incentives to ULBs to improve governance, financial management, own source revenues, and
8
operations and maintenance. Measures included in the project design to enhance the sustainability of BMDF as a financial intermediary in the long-term are: (i) preparation of a comprehensive BMDF long-term road map study; (ii) GoB agreement to allow BMDF to retain loan repayments (amounting to 20% of the IDA allocation) from MGSP-financed loans to ULBs, for future lending operations; (iii) GoB agreement to provide about US$7.5 million equivalent to BMDF as equity; and (iv) BMDF plan to improve efficiency of its operations to cover fully its operating costs using own source revenues by 2019. These measures will help improve the viability of BMDF operations, reduce systemic risks, and ensure its long-term sustainability as an open access funding window for financing municipal services investments of ULBs. 38. Environmental and social sustainability. A framework approach has been applied to the sub-projects. All sub-projects will require environmental and social screening, and sub-projects with significant impacts will require further impact assessment and mitigation plans. Social sustainability will be assured by building stakeholder ownership through enhanced participation of project affected persons (PAPs) and users in project design, implementation, monitoring and evaluation. The Suggestions and Complaints Mechanism will allow stakeholders to address grievances. V. KEY RISKS AND MITIGATION MEASURES
A. Risk Ratings Summary Table
Risks Rating
Project Stakeholder Risk
- Stakeholder Risk Moderate
Implementing Agency Risks
- Capacity Substantial
- Governance Substantial
Project Risks
- Design High
- Social and Environment Moderate
- Program and Donor Moderate
- Delivery Monitoring and Sustainability Substantial
Overall Implementation Risk Substantial
B. Overall Risk Rating Explanation
39. Project implementation risk is rated substantial because implementation agency risks related to weak governance, inadequate capacity, and delivery. Monitoring and sustainability risks are substantial, and project design risk is rated high. Project design includes necessary measures, by both LGED and BMDF, to mitigate the above risks including: (i) provision of consultant services support to ULBs; (ii) oversight of contract award decisions; and (iii) and joint
9
measurement of works and approval of payment certificates before payments are made to contractors. In addition, the Bank will provide intensive implementation support. The Operational Risk Assessment Framework (ORAF) in Annex 4 provides details of the risks and risk management measures. VI. APPRAISAL SUMMARY
A. Economic and Financial Analysis
40. Economic Analysis. As indicated earlier, the project will contribute to improved governance of ULBs and municipal management. The project will address under-investment in basic urban infrastructure services and operations and maintenance deficiencies. Since ULBs will finalize eligible sub-projects only during the project implementation phase, economic analysis at appraisal is based on the feasibility studies of 704 sub-projects proposed by participating ULBs in five focus areas: (i) drainage; (ii) urban transportation; (iii) sanitation and municipal facilities; (iv)water supply; and (v) solid waste management. Summary results of the economic analysis are presented in Table 1.
Table 1: Summary Results of Economic Analysis Project Components and main focus areas
Assessed project
proposal Cost (US$
million)
% of total component
cost
NPV @10% (US$ million)
EIRR (%)1
EIRR (%)2
B/C ratio
(-)
Component 1: 231 94% 206.6 21.8% 31.8% 1.90Drainage 78 32% 22.0 12.0% 24.0% 1.57Urban transportation 74 30% 117.0 29.0% 35.0% 2.90Sanitation and municipal facilities
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17% 64.0 34.0% 46.0% 1.35
Water supply 28 12% 3.6 12.0% 24.0% 1.10Solid waste 9 11% N.A. N.A. N.A. N.A. Component 2: 113.5 66% 138.4 26.5% 33.6% 2.06Urban transport 48 28% 76.0 29.0% 35.0% 2.90Municipal infrastructure 36.5 21% 55.0 34.0% 39.0% 1.35Drainage 24 14% 7.0 12.0% 24.0% 1.57Water supply 3 2% 0.4 12.0% 24.0% 1.10Sanitation 1 0.7% N/A N/A N/A N/ASolid waste 1 0.7% N/A N/A N/A N/A Total Component 1+2: 344.5 82% 345.0 23.0% 31.0% 1.901) EIRR includes the direct benefits of the improved basic services. The positive effects on the external environment, such as improved local governance and capacity benefits, health benefits, etc. are not included. 2) EIRR includes rough estimates of the expected external benefits, such as improved local governance and capacity as well as health benefits based on experience from similar projects.
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41. Financial Analysis. The financial analysis considered the potential income generating sub-projects, including bus/truck terminals, kitchen markets, public toilets, etc. Summary results of the financial analysis are presented in Table 2. The detailed financial analysis is provided in Annex 7. Table 2: Summary Results of Financial Analysis of Income Generating Sub-project Categories Income generating sub-projects
Cost (US$ million)
% oftotal cost
NPV @ 10%(US$ million)
FIRR (%)
B/C ratio(-)
Component 1: 19.05 8.35% 4.60 14.2% 1.33Bus/Truck Terminals 9.00 4.00% 2.30 14.0% 1.35Wholesale/Kitchen Markets
9.00 4.00% 1.75 14.0% 1.29
Public Toilets 0.70 0.30% 0.20 14.0% 1.26 Component 2: 19.00 17.00% 5.18 14.8% 1.35Bus/Truck Terminals 3.50 3.00% 0.90 14.0% 1.35Wholesale/Kitchen Markets
13.50 12.00% 3.00 14.0% 1.29
Slaughter Houses 1.00 1.00% 1.00 28.0% 2.24Public Toilets 1.00 1.00% 0.28 14.0% 1.26 Total Component 1+2: 38.05 - 9.78 14.5% 1.34 B. Technical
42. The project design will emphasize improvement/rehabilitation, repair and enhanced operations and maintenance, over new construction. Most investments proposed by ULBs under Components 1 and 2 are expected to include reconstruction or rehabilitation of roads, footpaths, culverts, drains and street lights. New construction will include markets and bus and truck terminals. The project also includes support for the under-funded O&M in the 26 ULBs, on a declining basis, with the requirement for ULBs to progressively increase their annual contributions to the O&M budget. 43. Basic urban services investments under Components 1 and 2 would represent needs and priorities of the ULBs, taking into account consultations with the communities, i.e., the Ward and Town Level Committees. Project technical assistance, under both components, will ensure that investments are prioritized, designs are least cost, and the works can be maintained by the ULBs. The rehabilitation works are simple, and LGED has standard designs for new investments in bus/truck terminals and produce markets. Other works do not require options analysis, complex designs or special construction techniques, and are within the technical capacity of ULBs to implement with support from LGED and its consultants. Design and Supervision Consultants will review the designs under both components to ensure their appropriateness and technical soundness. Sub-projects financed by BMDF will also be subject to BMDF appraisal to assess O&M and debt repayment capacity. Bank implementation support missions will also monitor the technical soundness of project works.
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C. Financial Management
44. LGED and BMDF participated in MSP, and are familiar with the Bank’s financial management (FM) and disbursement procedures. Financial management arrangements for each agency, described below, were finalized taking into account the capacity assessment update of both agencies. 45. LGED. Project financial management and disbursement functions in LGED will be supported by the Financial Management Specialist (FMS) of the PMU, who will be a professional accountant, capable of assessing the FM capacities of the ULBs and their eligibility for project funding, as well as monitoring utilization of project funds by ULBs. An Account Officer and two Accountants will be appointed from existing LGED staff, preferably with experience in Bank-funded projects, to assist the FMS. Funds to execute contracts under approved sub-projects of each ULB will be directly disbursed to the contractors’ bank accounts through electronic bank transfer from LGED’s Designated Account on the basis of the contractors’ invoices certified by ULBs, and approved by the Project Director. The FMS and all other FM staff will be identified for recruitment as soon as possible, but not later than February 28, 2014. 46. BMDF. FM functions under the project will include assessing the financial management abilities of the ULBs and eligibility for project funding, reviewing ULBs’ request for funds, disbursing loan funds to ULBs in accordance with the procedures to be agreed, and supervision and monitoring of the utilization of project funds by ULBs. The FM section of BMDF performed satisfactorily under MSP, and is assessed as adequate to undertake centralized financial management functions for MGSP. BMDF currently has six FM staff in place out of seven approved staff positions and it is in the process of filling the vacant position. BMDF will need to improve its capacity by engaging a Financial Management Expert to provide FM support to implement Component 2 of the project and to provide on-the-job training to FM staff. BMDF will identify the accounts staff and the FM Expert, preferably a professional accountant, as soon as possible but not later than February 28, 2014. 47. FM Risk. The main FM risk is the challenge to monitor activities of 26 pre-selected ULBs under the project and the potential 100 plus ULBs that will receive financing from BMDF, scattered spatially throughout the country. However, funds required to execute the contracts under approved sub-projects of each the 26 pre-selected ULBs will be directly disbursed to the ULB’s contractors’ bank accounts through electronic bank transfer from LGED’s Designated Account, on the basis of contractors invoices certified by ULBs, as well as approved by the Project Director. Other FM risks identified include the Fiduciary Management Risk (identified in the ORAF) and FM capacity risk as part of Institutional Capacity Risk. Project design has incorporated measures, including staffing and procedures, to mitigate the fiduciary risks arising from the weaknesses in internal control environment, and FM capacities through Project Financial Management.
D. Procurement
48. Procurement Capacity Assessment. A procurement capacity assessment of LGED and BMDF was conducted. As most of the works contracts are at the decentralized level (i.e.
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different ULBs), both LGED and BMDF will require adequate procurement support through consulting firms to manage procurement under this project. Though significant procurement capacity development was achieved by both LGED and BMDF under MSP, the ULBs still have weaknesses in bid evaluation and contract management. In addition to adequate staffing for procurement needs, emphasis will be placed on areas of internal control, documentation, information dissemination, administration of contracts including delivery follow-up, payments, handling complaints, etc. Several measures will be introduced to minimize risks during implementation of the project, including: (i) use of electronic tendering system developed by the Central Procurement Technical Unit of Bangladesh; (ii) procurement training, especially in bid evaluation and contract management for key staff of the project and relevant municipalities; and (iii) awareness training on fraud and corruption (F&C) issues both for project/municipal officials, and prospective bidders. These assessments and agreed action plans have been incorporated in the web-based Procurement Risk Assessment Management System (P-RAMS).
E. Social
49. Given the nature of the project, a framework approach has been selected for implementation of the social aspects of the project. Sub-project selection, design and implementation in each ULB will carried out during the project implementation period through an all-inclusive consultative process and participation of the communities. A Social Management Framework (SMF) has been adopted for social development and safeguards compliance of the project activities. The World Bank’s Operational Policies on Involuntary Resettlement (OP/BP 4.12) and Indigenous Peoples (OP/BP 4.10) have been triggered by the project. The SMF will guide LGED, BMDF and the ULBs to mainstream the social development agenda and to address social safeguard compliance issues during implementation. The SMF includes a social screening and assessment facility, a resettlement policy framework, an indigenous people’s framework and a social inclusion and gender framework. Social screening and assessment will be conducted for all sub-projects and Resettlement Action Plans (RAP) and/or a Tribal Peoples Plan (TrPP) will be prepared, where necessary.
50. ULBs will follow a bottom-up approach for identification, design and implementation of sub-projects and mainstream social development for inclusion, participation, transparency, social accountability and social safeguards compliance. Participation of all community groups including the very poor, women, tribal peoples and other vulnerable groups will be ensured through involving the Town Level Coordination Committee (TLCC) comprising of local stakeholders at the central level and the Ward Level Coordination Committees (WLCC) comprising of the beneficiary communities in each ward. Members of TLCC and WLCC will have representation from women and vulnerable groups. Both LGED and BMDF will review these processes and ensure social development process and outcomes in the sub-project cycle.
51. LGED has designed a Grievance Response Mechanism (GRM) for the resolution of complaints and grievances under the project. A Grievance Redress Committee (GRC) will be set up at each ULB to ensure accessibility by the communities and affected persons for resolving sub-project-related social and environmental grievances and those on procurement and quality of works. Where tribal peoples (TP) are among the beneficiaries and affected persons, the membership composition of the GRCs will take into account any traditional conflict resolution
13
arrangements that TP communities may practice. A full description of the GRM is provided in the SMF. 52. The SMF has been developed based on a social assessment, including field consultation, capacity assessment, and review of local laws and the Bank policies on social safeguards. The draft SMF report was made available to the Association for safeguard review on August 18, 2013 and updated after comments from the Association. The updated SMF was re-submitted to the Association on September 3, 2013 for final clearance. The draft SMF has been disclosed locally in the LGED and BMDF websites (www.lged.gov.bd, www.bmdf-bd.org)and disclosed in the World Bank Infoshop for public comments.
F. Environment
53. Basic urban infrastructure facilities financed by the project are not expected to cause any long term or irreversible environmental impacts. The project is classified as a Category B project and the Environment Assessment (OP/BP 4.01) safeguard policy has been triggered. The Natural Habitats (OP/BP 4.04) and Physical Cultural Resources (OP/BP 4.11) safeguards policies have been triggered as a precautionary basis. 54. Since sub-projects will be identified during the project implementation phase, a framework approach has been adopted for the project. The Environmental Management Framework (EMF) prepared meets the requirements of the Department of Environment of Bangladesh and the World Bank Environment Safeguard Policy. The EMF has been prepared based on: (i) assessment of the environmental practices of the recently completed MSP; (ii) evaluation of the potential overall environmental impacts of the sub-projects; (iii) sub-project specific standard environmental mitigation and monitoring plans, with unit costing; (iv) public consultations during project preparation; (v) identification of the institutional barriers and capacity building needs for environmental management; and (vi) institutional arrangements for environmental management. In addition, the relevant Environmental, Health and Safety Guidelines of the World Bank Group/International Finance Corporation (IFC) will be applicable to the project. The draft EMF document with the Bangla version was disclosed both in the LGED and BMDF websites (www.lged.gov.bd, and www.bmdf-bd.org) on September 24, 2013 and the Bank’s Infoshop on September 24, 2013 for public comments. Hard copies of the document have also been made available in all field offices related to the project’s implementation. The disclosure notification has been published in a Bangla daily newspaper an English daily newspaper on September 24, 2013. 55. The EMF will be the guiding document for sub-project-specific: (i) environmental screening; (ii) environmental assessment; (iii) environmental consultation and disclosure; (iv) preparation of environmental management plan (EMP) with budgeting; (iv) implementation and supervision of the EMP; and (v) reporting and quality control. All sub-projects will be screened to assess the extent of environmental assessment required. 56. Both LGED and BMDF have previous experience in implementing the environmental management framework, and LGED in particular has developed reasonable institutional capacity for its implementation. The project will support further capacity building of LGED on mainstreaming environmental management in urban infrastructure. An assessment of the
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performance under MSP, including institutional capacity, identified the areas where further capacity strengthening is required. Bank missions will supervise environmental compliance as part of regular implementation support missions. 57. In order to ensure proper environmental management in the project, independent environmental auditing will be carried out by independent consultants. Terms of reference (TOR) for the independent consultants has been included in the EMF.
G. GAAP and Third Party Monitoring
58. A Governance and Accountability Action Plan (GAAP) has been developed and discussed with the relevant implementing agencies. Specific measures of the GAAP have been incorporated under Component 1, Component 2, and Component 3 of the project. The GAAP will be monitored through the performance assessments carried out for the ULBs. Under Component 3, the Local Government Division (LGD) has agreed to perform the Third Party Monitoring, which will be contracted out to independent consultants. The Third Party Monitoring will include spot check exercises and will examine whether program implementation guidelines are followed, whether program benefits reach the intended beneficiaries, and the accountability of the public financial management systems at the local level. Process assessments and spot checks will be conducted in a random sample of ULBs. Instruments for the assessment will be discussed and agreed with the Association.
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Annex 1: Results Framework and Monitoring
BANGLADESH: Municipal Governance and Services Project (MGSP)
Project Development Objectives (PDO): The PDO is to improve municipal governance and basic urban services in participating ULBs, and to improve the Recipient’s capacity to respond promptly and effectively to an Eligible Crisis or Emergency.
Project Development Objective Indicators
Indicator Name Core Unit of Measure
Baseline Cumulative Target Values
Frequency Data Source/Methodology
Responsibility forData Collection YR1 YR2 YR3 YR4 YR5 YR6 YR7
End Target
Number of people in urban areas provided with improved basic services
Number (in thousands)
0 - 586 1,243
1,905 2,616 3,430 3,430Annually
LGED& BMDF records
LGED, BMDF
Percentage of female beneficiaries
Percentage Sub-Type Supplemental
0 45 45 45 45 45 45 Annually LGED& BMDF records
LGED, BMDF
Percentage of ULBs (among 26 ULBs) demonstrating improvement in the annual performance assessment
Percentage 0 20 40 60 80 100 100 Annually
Municipal Perf.
Assessmt. under MGSP
LGED
Contingent Emergency Appropriation
Triggered if Requested
N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
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Intermediate Results Indicators
Indicator Name Core Unit of
Measure Baseline
Cumulative Target Values Frequency Data
Source/ Methodol
ogy
Responsibility for Data
Collection YR1 YR2 YR3 YR4 YR5 YR6 YR7
End Target
Percentage of participating ULBs with a municipal tax collection rate at 80% of invoiced tax bills
Percentage (%)
0 - 20 40 60 80 100 100 Annually
Municipal Perf.Assessmtunder
MGSP
LGED
Percentage of participating ULBs with arrangements for operations and maintenance established.
Percentage (%)
0 - 20 40 60 80 100 100 Annually
Municipal Perf.Asse
ssmt under MGSP
LGED
Number of ULBs with improved financial and investment planning.
Number 0
0 0 25 50 70 85 100 100
Annually
BMDF records
BMDF
For ULBs borrowing from BMDF, Loan repayment ratio
Percentage 80 80 80 82 84 86 88 90 90 Annually
BMDF Records
BMDF
Incremental operating cost covered by own source revenue
Percentage 25 25 25 40
60 80 100 100 Annually BMDF Records
BMDF
Number of ULB staff incl. community people trained by LGED and BMDF
Number 0 - - 50,00
0100,000
144,000 144,000 144,000 144,000 Annually
MSU/ LGED/ BMDF
LGED/ BMDF
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Annex 2: Detailed Project Description
1. Municipalities and City Corporations in Bangladesh, commonly referred to as urban local bodies (ULBs), are growing rapidly and continue to play key roles in supporting economic growth, jobs creation and poverty reduction. However, they face several challenges that constrain them from developing into competitive, innovative and livable places. The constraints are weak municipal finances and governance systems, insufficient administrative capacity, and inadequate basic urban services. MGSP will contribute to improving basic urban infrastructure services and municipal governance in 26 pre-selected ULBs, and demand-based financing window by BMDF for urban services improvement through activities described below. Component 1 - Municipal Governance and Basic Urban Services Improvement (Total Cost US$246.35 million; IDA US$204.00 million). 2. Objective. This component will provide financial support to 26 pre-selected ULBs with high economic growth and job creation potential, and located along the three growth corridors leading from Dhaka towards Chittagong, Rangpur, Sylhet, Mymensingh, and also including three district towns in the South. These ULBs were selected based on: (i) analytical evidence on urbanization and growth in Bangladesh; (ii) preparatory frameworks for municipal development intervention; and (iii) a diagnostic study carried out under MSP Additional Financing in early 2012. These additional financial support will boost basic urban services delivery and improve urban governance in the pre-selected 26 ULBs. The table below summarizes the socio-economic and fiscal status of the 26 ULBs.
Table. Socio-economic and Fiscal Capacity of 26 ULBs
Name Pourashava/
City-Corporation
Class Total
population in 2011
2010/2011 Budget
2010/2011 Revenue2
2010/2011 Expenditure
Bhairab Pourashava A 125,000 364,250,000 55,356,987 50,620,526Bhaluka Pourashava A 160,000 47,727,520 38,727,520 36,094,000Chouddagram Pourashava B 37,962 13,800,000 7,722,740 5,777,950Chakoria Pourashava A 118,530 118,350,000 16,931,088 14,172,913Chandina Pourashava B 70,000 127,867,341 68,255,000 64,632,500
Comilla City Corporation CC 235,423 282,503,662 171,050,293 262,051,903
Daudkandi Pourashava B 42,830 22,673,266 13,589,396 12,359,652
Elenga Pourashava C 55,000New
pourashavaNew
pourashava New
pourashavaFeni Pourashava A 300,000 422,621,000 136,690,063 62,523,758Gobindaganj Pourashava B 40,676 83,675,000 10,550,000 9,663,301Gopalgonj Pourashava A 114,950 193,663,718 41,258,000 42,147,730Madaripur Pourashava A 112,500 54,257,195 32,634,602 30,243,759Madhabdi Pourashava A 28,700 40,478,152 28,201,379 24,511,000
2 Revenue and Expenditure refer to ULBs own source revenue and expenditure.
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Madhabpur Pourashava A 40,000 41,407,990 13,486,139 13,256,120Mirsharai Pourashava B 20,071 7,075,000 6,874,624 6,698,481
Narayanganj City Corporation CC 709,381 438,935,963 217,946,757 4,335,169,50
0Patia Pourashava A 50,120 112,796,000 22,895,000 20,799,000
Rangpur City Corporation CC 360,059 256,381,000 130,947,069 194,291,000
Saidpur Pourashava A 163,503 204,510,430 97,010,430 94,561,000Shaistagonj Pourashava A 26,779 20,635,670 9,974,893 8,797,497Shariatpur Pourashava A 59,129 384,773,892 28,877,883 28,877,883Sherpur Pourashava A 92,216 80,500,000 27,383,465 28,857,182Shitakunda Pourashava B 62,011 118,176,075 10,954,075 107,222,000
Sylhet City Corporation CC 485,138 2,681,970,000 203,692,000 509,473,000
Tangail Pourashava A 345,855 696,416,735 248,565,000 246,090,000Trisal Pourashava A 35,030 65,794,141 91,015,000 19,150,000 3. This component will include two sub-components: (i) a base allocation to all pre-selected ULBs, and a performance-based allocation (to be rolled-out on an annual basis from the third year of the project) provided to ULBs that demonstrate improvements in basic urban services and urban governance, focusing on municipal planning, social accountability, public financial management and revenue mobilization; and (ii) an O&M allocation to support improvements in operations and maintenance, on a declining basis. Following project effectiveness, all ULBs will be informed of their indicative six-year allocations for each of the sub-components. This will in turn allow ULBs to develop 5-year capital investment plan- (CIP) to undertake visible and high impact urban services, and identify methods to improve urban governance. A key activity underlying the cycle of the sub-projects to be undertaken is the participation of the citizens through representation at the Ward-Level Coordination Committees (WLCC), Town-Level Coordination Committees (TLCC), and the municipal councils, including during the social and environment sub-project screening. Sub-projects will be selected annually from priority investments indicated in the CIP. 4. Implementation Partnership Agreement. Prior to receiving project funds, each of the 26 ULBs will sign a Implementation Partnership Agreement with LGED, which will require ULBs to: (i) prepare the capital investment plan for the 5-year base allocation; (ii) prepare an annual O&M plan starting from July 1, 2015; (iii) prepare and implement sub-projects as per agreed norms; (iv) demonstrate improvements to own source revenue mobilization; (v) improve basic urban services and governance, as measured by the performance indicators; and (vi) and comply with safeguards and other requirements, described in the Project Implementation Manual.
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5. Eligible Investments. The eligible investments under MGSP includes: basic urban services in low income settlements/areas; road improvement/rehabilitation; new roads/footpaths; storm drainage; bridges and culverts; public toilets; solid waste collection and disposal (trash bins, carts, tractor/trailers); car parks; streetlights; traffic management facilities; pedestrian underpasses or overpasses; wholesale/kitchen markets; bus/truck terminals; rehabilitation of water supply systems; and other basic urban services agreed by the Association. Within the existing resource envelope, each ULB will prioritize its own investments drawing from this list of eligible investment options. Investments that pose higher fiduciary and accountability risks, such as cars or trucks, other than specific-purpose vehicles, will not be eligible for financing under the project.
6. Readiness of investment sub-projects. ULBs will receive technical support from LGED to advance preparation of first year investment sub-projects, including completed bid documents and capacity enhancements. ULBs will be informed of the notional base allocations and performance-based allocations over the project period, thus assuring them of a predictable fund flow to enable proper planning and implementation of sub-projects. Sub-component 1(a): Provision of Financial Support to 26 Pre-selected ULBs for the carrying out of sub-projects aimed at improving the delivery of basic urban services. 7. Base Allocation (IDA US$133 million; GoB US$20 million). The base allocation constitutes 75 percent of the combined base and performance-based allocation. The 26 ULBs will receive on an annual basis a predetermined amount of funds for financing basic urban services. The base allocation will be determined on the basis of a simple and transparent formula that takes into account each ULB’s population size and classification (i.e. Class A, Class B, Class C type of Pourashavas and City Corporations)3. Class A Pourashavas will receive a lump sum of US$500,000 annually; Class B and C will receive a lump sum of US$250,000; and each City Corporation will receive US$750,000. The notional annual average base allocation to be distributed among the 26 ULBs will be US$25.5 million; on average, each ULB will receive
3Class A are Pourashavas with revenues over Taka 6 million; Class B are Pourashavas with revenues between Taka 2.5 million and Taka 6 million and Class C are Pourashavas with revenues up to Taka 2.5 million.
Improve basic urban services and urban governance
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US$0.98 million per annum (US$ 11.7 per annum on a per capita basis). The annual allocations have factored in the possibility of relatively low absorption in the initial two years, with expenditures likely to progressively increase to peak in the third and fourth years of the project. Subsequently, the base allocation will gradually reduce, reaching zero in the last year of the project.
Table 1: Distribution of Total Grant Allocation Over the Project Period (US$ Million)
Base Allocation Performance-Based Allocation
Total Grant Allocation
Year 1 22,950,000 0 22,950,000 Year 2 24,480,000 0 24,480,000 Year 3 38,250,000 12,750,000 51,000,000 Year 4 39,780,000 12,750,000 52,530,000 Year 5 27,540,000 12,750,000 40,290,000 Year 6 0 12,750,000 12,750,000 Total 153,000,000 51,000,000 204,000,000
8. Performance-Based Allocation (IDA US$51 million). Ten simple and measurable indicators (see table 2 below) have been derived through consultation with LGED, taking into account experience in other completed and/or ongoing donor-supported projects. The performance-based allocation will be provided over four years, starting in the third year, with a notional total allocation of US$12.5 million per year (see middle column of Table 1 above). On average, each ULB will receive about US$1.46 million per annum (US$20.46 per annum on a per capita basis)as the combined base allocation and performance-based allocation), if it passes with a “Very Good” score. 9. In the first year, extensive information, education and communication (IEC) campaigns and capacity support will be provided to all ULBs. In the second year, an independent firm will undertake the first performance evaluation, on the basis of which performance-based allocations will be awarded from the beginning of the third year. The performance evaluations will typically take place 4-6 months prior to the beginning of the relevant budget year, so that ULBs are able to adopt their municipal budget in line with their grant allocation. LGED will play a critical oversight role to ensure that the evaluation process is carried out with a high degree of integrity and professionalism. The results of the assessment will be announced publicly. The performance evaluation system will be reviewed during the project’s mid-term review for any refinements to ensure flexibility and to confirm that it is providing the desired incentives for ULBs to improve urban governance. 10. For each performance indicator, the ULB will either receive a pass (for a score of 1) or a fail (for a score of 0). ULBs that score less than 5 (the lowest band) will be considered to have failed the performance assessment process in that fiscal year and will not receive any performance-based allocation for the next two fiscal years. ULBs that achieve an aggregate score of 5, 6 or 7 will be considered to have passed the assessment with a “Good” grade and will receive a performance bonus equivalent to 75% of their notional annual performance-based allocation. ULBs that achieve an aggregate score of 8, 9 or 10 will be considered to have passed
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the assessment rated “Very Good”, and will receive a performance bonus equivalent to their full notional annual performance-based allocation. Unallocated performance-based allocations will be pooled with the performance-based allocations for the fifth year and sixth year, and a revised notional performance-based allocation for those years will be announced. ULBs that fail during the first performance evaluation process will also be provided capacity support to prepare them for the subsequent performance-based allocation process for Year 5 and Year 6 allocations. The ULBs that fail during the second performance evaluation process will not receive any performance-based allocation, the rest allocation will be distributed to only qualifying ULBs.
Table 2: Performance Indicators Areas/Elements Performance Requirements/Activities Score A: Municipal Planning Processes: Integrated municipal planning, including master planning, capital investment planning, and environmental planning A1 Capital Investment Plan Capital Investment Plan prepared, consultations
performed with TLCC and WLCC, adopted by the council, and available to the public.
1 point
A2 Annual O&M plan Annual O&M plan, including budget requirements, adopted by the council, and available to the public.
1 point
B. Social accountability strengthening: Citizen awareness and participation, participatory and inclusive planning, women’s participation and pro-poor urban development
B1 Town Level Coordination Committee (TLCC) and Ward Level Coordination Committee (WLCC)
TLCC & WLCC formed, provided TORs, and functioning effectively (conforming to given ToR, meetings convened at least once every 3 months, meetings announced and open to the public, with active participation of women and poor ensured, minutes shared publicly).
1 point
B2 Grievance Redress Cell (GRC) GRC formed and functions in conformity with the ToR. GRC receives and addresses complaints/grievances.
1 point
B3 Inclusive Budget Process Date and location of Public Budget Hearing announced in the local media at least 30 days in advance.
Pourashava budget proposal, with prior year data, is made public 15 days prior to the Public Budget Hearings.
Pourashava budget proposal discussed in TLCC meetings.
1 point
C. Public Financial Management & Public Revenues: Accountability and Sustainability PFM strengthening, revenue enhancing action plans, and financial accountability C1 Computerized accounting system and computer-generated accounting reports (including computerized tax-record system and computer-generated billing reports)
Computerized accounting system installed and being used; computer-generated accounting reports produced for Pourashava Council and made public.
Computerized tax-billing system installed and used; 100% invoices issued; and computer-generated tax-billing reports for the Pourashava Council and made public.
1 point
C2 Property assessment carried out regularly
Property assessments and interim tax assessments carried out regularly.
1 point
C3 Tax collection effort Collection increased to (and retained at) a minimum of 80% of invoiced tax bills.
1 point
C4 Non-tax own revenue source management
All non-tax revenue sources identified & taken into account with increase in such revenue equal at least to the official inflation rate.
1 point
C5 Settlement of outstanding bills, especially for services (power & telephone, etc.) by GoB & other agencies during project implementation period.
Outstanding service bills (3 months & over), especially to GoB/service providers, settled & report sent to the PMU.
1 point
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Total Score 10 11. A detailed projected simulation of the base allocation and the performance-based allocation for each of the pre-selected ULBs under the project are shown in the Project Implementation Manual. 12. Budgeting, Planning and Execution. The base allocation and performance-based allocations will be programmed, and the projects in each ULB will be prepared and executed using existing planning, budgeting, and implementation procedures at LGED, building on the systems developed under the Municipal Services Project (MSP). The parameters for the financial support model will initially remain fixed until the project mid-term review (MTR) when the experience and lessons learned will be examined and relevant adjustments may be made. Sub-component 1(b):Financial Support for Operations and Maintenance (O&M)(IDA US$20 million, ULBs US$8 million). 13. This sub-component will provide financial support to address the O&M challenges faced by ULBs through systematic O&M planning and budgeting on a pilot basis. The aim is to develop a culture of responsible operations and routine periodic maintenance of infrastructure assets. 14. O&M Allocations. The O&M financial support of US$20 million will be provided to the 26 ULBs over a six year period, on a declining basis. A realistic baseline and conservative rate of increase in ULB O&M budgets has been adopted. The declining annual allocations of the O&M allocation will be partially matched by increased ULB O&M contributions, to reach US$8 million in the sixth year. See table below.
Year 1 Year 2 Year 3 Year 4 Year 4 Year 6 Total
Declining O&M Allocation 6.67 5.33 4.00 2.67 1.33 0.00 20
Increasing ULB O&M Budget 0 0.53 1.07 1.6 2.13 2.67 8
15. O&M Plan Preparation. Each ULB will prepare an O&M Plan no later than January 1, 2015, with the help of project consultants engaged by the LGED. The O&M Plan will include: (i) establishment of a separate O&M budget item in the ULB accounts; (ii) establishment of current (baseline) expenditures for O&M (for 2012/2013); (iii) an optimum O&M implementation plan, including the frequency of maintenance for each type of asset, and requirements of manpower, materials and supplies and tools and equipment, and annual costs; and (iv) a realistic annual O&M budget for each year until 2020, taking account of the available ULB budget, proposed revenue enhancements, new assets constructed, and inflation.
16. ULB Commitment to Increase O&M Budget Allocations. Each ULB will make a commitment, through a Council Resolution, to increase own source allocations to the O&M budget each year by specific amounts, starting June 2015, from the current baseline to reach the agreed O&M budget level by Year 2020.
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17. Procedures for O&M Allocations. All 26 ULBs will be allocated the O&M financing from the period of Credit effectiveness to June 30, 2015 without any conditions or requirements. O&M allocations from July 1, 2015 will be made (by June 2015) subject to the preparation and submission of a satisfactory O&M Plan (budget, resources and activities), a ULB Council Resolution committing to increase O&M budgets annually to specified levels, and satisfactory performance in the use of the first year O&M allocation and preparation of O&M plan for five years. 18. Use of O&M Allocations. The O&M allocations will be used only for maintenance works (and not for new construction) of roads, drains, public toilets, water supply pumps or pipelines, solid waste collection, and street lights. Eligible O&M activities will include routine and periodic maintenance of urban roads, drainage system, street lights, markets, public toilets and solid waste collection and street cleaning. Eligible expenditures will include: contract labor, fuel, bitumen, small equipment hand tools, etc. O&M allocations will not be used to pay utility bills or other dues owed by the ULB, or for purchase of large or heavy road construction equipment. Maintenance works may be implemented either by force account or through annual maintenance contracts. In order to facilitate the roll out of this program, LGED will make advance transfers of the O&M allocations to the bank account of the ULBs. Component 2: BMDF Demand-based Financing for Basic Urban Services (Total Cost US$ 171.50 million; IDA US$ 155.00 million). 19. This component includes: (i) US$155 million to BMDF to provide demand-based financing through grants and loans to ULBs in Bangladesh for improvement of basic urban services. 20. BMDF will provide demand-based financing to ULBs through a mix of loans and grants based on transparent and objective eligibility criteria. Financing will be based on sub-project appraisal, financial performance and borrowing capacity of ULBs. This component will also assist ULBs in capacity building and developing and implementing sub-projects consistent with BMDF requirements. In addition this component will support the development of a road map for the future sustainable operations of BMDF, improvement of appraisal procedures and operations, and capacity building for its staff. 21. Eligible Sub-sectors. While most sub-sectors under municipal jurisdiction will be eligible for financing, BMDF will focus on roads, drainage, water supply, sanitation, solid waste management, small markets, bus and truck terminals, and municipal services centers, etc. BMDF will balance investments across sub-sectors to avoid overexposure to any particular sub-sector. 22. Selection of ULBs for Financing. Upon receiving an application for financing from an ULB, BMDF will conduct a screening to assess the institutional and financial situation of the ULB and decide whether the ULB is eligible to borrow and how much the borrowing capacity is with ULB’s own source revenue. BMDF will then invite ULBs that meet the screening criteria to start project preparation and submit detailed project proposals for appraisal by BMDF. Consultants, recruited under project technical assistance, will work together with WLCC/TLCC
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to help ULBs to prioritize investment needs and provide advice in preparing sub-project proposals that comply with the criteria and procedures of BMDF, and assist ULBs in procurement and construction supervision. BMDF will conduct sub-project appraisals, with assistance from consultants if needed, design review and implementation monitoring. 23. Financing Procedures and Lending Terms. BMDF will provide financing on the following terms, conditions and procedures: IDA credit financing of US$155 million will be provided to ULBs partly as a loan of 20%
and partly as a grant of 80% of IDA allocation. ULBs will be required to provide a contribution of 10% of the total proposed investment
costs. BMDF will finance 90% of the eligible investment costs, on a grant to loan ratio of 80:20.
Depending on individual ULB’s demand, financial condition and borrowing capacity, the loan portion may be higher than 20%.
Interest rate for the loans will be 5% per annum. However, the interest rate may be adjusted upwards by the BMDF Board based on the market conditions. The loan repayment period will be 10 years, with a one year grace period.
BMDF will require borrowing ULBs to: (i) set up an escrow account at a commercial bank, with adequate funds transferred from the ULB’s own source revenue to meet their loan principal and interest payment obligations; (ii) formulate and implement O&M of assets; and (iii) implement a revenue enhancement action plan to increase own source revenues.
BMDF will not provide financing, i.e., grant or loan, to any ULB that is in default of its financial obligations from previous operations.
24. Sub-project Appraisal Process. Sub-project proposals financing by BMDF will need to: (i) be part of the priorities under the ULB’s city development plan; (ii) be technically feasible and least cost; and (iii) comply with all environmental and social safeguards requirements of GoB and the World Bank. BMDF will appraise the ULB’s borrowing capacity. The loan amount will be based on the repayment capacity of the ULB as an entity. BMDF will use standard appraisal techniques and lending criteria such as the operating ratio and the debt service coverage ratio as its lending criteria. BMDF will include covenants in its loan agreements requiring increases in revenue collection, and improvement in O&M. 25. Sub-project Preparation: BMDF will engage consultants to develop standard templates for sub-project proposals and to support review of detailed designs, drawings, bidding documents and implementation support. The ULBs will prepare sub-project proposals through hiring consultancy supports by their own fund. BMDF will supply the ToR for hiring consultants and standard templates to the ULBs. 26. Sub-project Proposal Requirements: Each sub-project proposal will be evaluated to ensure that it meets the following criteria:
Cost Recovery. Appropriateness of cost recovery mechanisms. BMDF will encourage commercial pricing of services and adequate cost recovery wherever possible.
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Private Sector Participation. Assessment of costs and benefits, and the effectiveness of the private sector providing the service, considering current staff levels and capacity.
Implementation. Availability of adequate capacity and implementation arrangements and schedules.
Property Records. Plan to update the asset register, including satisfactory valuation. Procurement. Procurement complying with Bank procurement guidelines, and use of
agreed standard bidding documents (SBD). Capital Improvement Program. Sub-project proposals as part of an overall program of
capital and works improvement (including new and rehabilitation) program, encouraging a planned, programmatic approach toward capital infrastructure planning.
Viability. Information to demonstrate technical viability and cost effectiveness. Environmental and Social Safeguards. Meet Bank requirements for assessment of
environmental and social impacts and mitigation measures, consistent with the Environmental and Social Framework adopted by BMDF.
Land Use. Compliance with local land use regulations and the development plan. Economic Rate of Return. Economic rate of return of at least 12 percent.
27. Other Operational Aspects. These include:
(a) Fees and Charges. Fees and charges for processing of financing operations will be fixed by
BMDF to cover the costs of processing a financing operation. The current service charge for processing is a one-time fee of 1.0% of the grant portion of the Sub-project cost. This service charge may be revised based on market condition upon approval by the BMDF Board of Directors.
(b) Funds Disbursement. ULBs will be responsible for awarding contracts and for payments to contractors. Upon approval of a financing operation, the ULB will open a sub-project escrow account in a commercial bank. When payment certificates are issued, after joint measurement of works by the ULB Engineer and the project consultant, BMDF will transfer the required funds to the ULB project account. The Mayor or Chief Executive Officer will make payments to the contractor.
(c) Monitoring and Evaluation. Progress in achieving results will be measured against the set of
indicators presented in the Results Framework in Annex 1. 28. Improving Sustainability of BMDF Operations. The following actions will be implemented concurrently with MGSP to reduce default risks, and improve the sustainability of BMDF operations and its long-term development:
(i) GoB will permit BMDF to retain loan repayments of about 20% from IDA allocation from MGSP for future lending to ULBs.
(ii) GoB will permit BMDF to retain 4% of interest from MGSP lending, and will require it to remit 1% interest to MoF to service the IDA credit.
(iii) GoB will strengthen the capital base of BMDF with an injection of BDT 600 million (approximately US$7.5 million) as equity and seed money for future operations (the first transfer of US$1.25 million equivalent was made on June 19, 2013).
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(iv) BMDF will develop a business plan and strategic road map for its long-term development and operations, and assess its role in urban development financing, Bangladesh debt market, and lender and borrower’s capacity. BMDF will implement a series of measures to strengthen its institutional health through improving asset quality and earnings, and separating loan and grant operations and accounting.
(v) BMDF will take necessary measures to cover 100% of its operating costs from its revenues (i.e., service charge and interest) by 2019.
Component 3: Capacity Building and Implementation Support (Total Cost US$53.91 million; IDA US$51.00 million). 29. Under this component, the project will support capacity building and implementation support activities carried out by LGED, BMDF and LGD. Details of activities to be funded under this component are provided in the Project Implementation Manual (PIM). 30. Sub-component 3(a): Summary of Capacity Building and Technical Assistance for ULBs and LGED implemented by LGED is provided in the table below.
Component Activities Social assessment Consultant services Environmental assessment Consultant services Preparation activities Designs, training and workshops Design supervision and management, and O&M planning
Assist 26 ULBs in design of sub-projects and O&M plans, prepare complex designs, and assist LGED in supervising works, payment certifications, and in training ULB engineers.
Governance improvement and capacity building, and Project results monitoring
To assist ULBs to achieve performance targets, provide capacity development, project results monitoring
ULB performance evaluation Annual ULB performance evaluation National municipal performance monitoring system
Monitoring ULB performance and reports for LGD decision-making.
GIS-based property and asset management system
Demonstrate improved property and asset valuation to enhance ULB revenues.
Piloting municipal finance management
Piloting innovations based on regional experience.
Individual contract staff Expert services, including Financial Management Specialist required during implementation, and developing a national ULB monitoring system for LGD.
Studies Studies relevant to the mandate of LGED Study tours For staff of LGED, LGD, ULBs, etc.
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Financial management specialist Assist ULBs in developing FM capacity. Operational audit Conduct technical audits of sub-projects implemented
by the 26 ULBs. Financial audit Conduct financial audits of LGED and 26 ULB
accounts. Support to MSU for training activities
Expert consultant support for MSU, and computer hardware and software for ULBs.
Office equipment, maintenance equipment for LGED and ULBs
Office and IT equipment for LGED; construction and maintenance equipment for ULBs, and vehicles.
31. Sub-component 3(b): Summary of Capacity building and TA support to BMDF and to ULBs financed by BMDF (managed by BMDF) summarized as follows:
Component Activities BMDF Institutional strengthening
Roadmap study BMDF market study Operation Support & Capacity Building for BMDF
Management & Supervision Assistance to the ULBs in supervision, Quality & Quantity control, procurement, implementation management, bill certification, ensuring implementation of EMF & SMF provisions, redesigning for variation works etc. The consultants will provide supports to BMDF to review designs, project proposals, bidding documents of sub-projects, etc.
Appraisal support Individual consultant support to BMDF for sub-project appraisal on finance, civil engineering, environmental and social safeguards. Support BMDF to develop standard templates for Sub-project proposals and appraisals.
MIS Software development, application and web portal for BMDF and ULBs.
Training Training and workshops for Mayors, BMDF and ULBs’ officials.
Office equipment Office equipment and vehicle. Operation budget support Contract staff, including Procurement Specialist and Financial
Management Specialist. 32. Sub-component (c): Third Party Monitoring Supervised by the Local Government Division (LGD). The project will provide funding to LGD to engage consultants to undertake Third Party Monitoring for the Governance and Accountability Action Plan (GAAP). Component 4: Contingent Emergency Response (Total Cost US$0) 33. Bangladesh is finalizing its application to the Bank for participating in the IDA Immediate Response Mechanism (IRM). The draft Operational Manual has been prepared, and
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final discussions are underway to agree on the list of IRM Source Projects and Contingent Emergency Response Component (CERC) projects. 34. Following an adverse natural or man-made event that causes a major disaster, the Government may request the Association to re-allocate project funds to this component (which presently carries a zero allocation) to support response and reconstruction. This component could also be used to channel additional funds that may become available as a result of the emergency. 35. Disbursements under the Contingent Emergency Response Component (CERC) will be contingent upon the fulfillment of the following conditions: (i) GoB has determined that an eligible crisis or emergency has occurred and the Bank has agreed with GoB’s request; (ii) the Ministry of Finance has prepared and adopted the Contingent Emergency Response (CER) Implementation Plan that is agreed with the Bank; and (iii) LGED has prepared, adopted and disclosed safeguards instruments required as per Bank guidelines for all activities eligible for financing under the CERC.
36. Disbursements would be made either against a positive list of critical goods and/or the procurement of works and consultant services required to support immediate response and recovery needs. All expenditures under this component, should it be triggered, will be in accordance with BP/OP 10.00, and will be appraised, reviewed and found to be acceptable to the Bank before any disbursement is made. 37. Specific eligible expenditures under the category of Goods include: (i) construction materials; water, land and air transport equipment, including supplies and spare parts; (ii) school supplies and equipment; (iii) medical supplies and equipment; (iv) petroleum and fuel products; (v) construction equipment and industrial machinery; and (vi) communications equipment. 38. Specific eligible expenditures under the category of Works may include urgent infrastructure works (repairs, rehabilitation, construction, etc.,) to mitigate the risks associated with the disaster. 39. Specific eligible expenditures under the category of Services may include urgent studies (either technical, social, environmental, etc.,) necessary as a result of the effects of the disaster (identification of priority works, feasibility assessments, delivery of related analyses, etc.).
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Appendix to Annex 2: Project Costs by Component (US$ million)
Sl. No. Component Base Cost
Total Cost including Contingency
IDA GoB ULBs
1 MUNICIPAL GOVERNANCE AND SERVICES IMPROVEMENT
223.95 246.35 204.00 34.35 8.00
1.1 Base Allocation and Performance-based Allocation 185.45 204.00 184.00 20.00
1.2 Improvement of Operations and Maintenance 25.45 28.00 20.00 8.00
1.3 Land Acquisition, Resettlement, and Livelihood Restoration 6.23 6.85 0.00 6.85
1.4 Customs Duty for Internationally Procured Goods and Equipment 6.82 7.50 0.00 7.50
2 BMDF FINANCING FOR DEMAND-BASED URBAN SERVICES
155.90 171.5 155.00 0.00 16.50
3 CAPACITY BUILDING AND IMPLEMENTATION SUPPORT
49.01 53.91 51.00 2.91 0.00
3.1 LGED Capacity Building and Implementation Support 41.05 45.15 42.24 2.91 0.00
Technical Assistance 16.62 18.28 18.28 0.00 0.00
Goods, equipment and vehicles 15.95 17.55 17.55 0.00 0.00
New Project Preparation 1.82 2.00 2.00 0.00 0.00
Environmental, Social Assessment & other preparatory activities 0.16 0.18 0.18 0.00 0.00
LGED Incremental contract staff cost (PMU+MSU+PIU) 6.49 7.14 4.23 2.91
3.2 BMDF Capacity Building and Implementation Support 7.05 7.76 7.76 0.00 0.00
3.3 Third Party Monitoring (supervised by LGD) 0.91 1.00 1.00 0.00 0.00
4 CONTINGENT EMERGENCY RESPONSE 0.00 0.00 0.00 0.00 0.00
Total Baseline Costs 428.87
Physical contingencies 21.44
Price contingencies 21.44
Total Financing Required 471.76 471.76 410.00 37.26 24.50
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Annex 3: Implementation Arrangements
Project Institutional and Implementation Arrangements
1. A Project Steering Committee (PSC) will be established in the Local Government Division (LGD), chaired by the Secretary of LGD, including representative form MoF and other relevant agencies, to provide overall guidance and policy direction. The Local Government Engineering Department (LGED) will be responsible for Component 1 and Subcomponent 3(a) of Component 3. The Bangladesh Municipal Development Fund (BMDF) will be responsible for Component 2 and Subcomponent 3(b) of Component 3. The Monitoring and Evaluation Wing of the Local Government Division (LGD) will supervise the Third Party Monitoring activities Subcomponent 3(c) to be carried out by consultant.
2. LGED Project Management Unit (PMU) will include a Project Director as well as a Project Coordinator, who will be a senior engineer of LGED experienced in World Bank projects and other requisite staff at LGED headquarters. The PMU responsibilities include: (i) preparation and execution of Implementation Partnership Agreements with the 26 ULBs before credit effectiveness; (ii) preparation of the first year sub-projects; (iii) selection and management of consultants to assist ULBs and LGED in sub-project preparation, project management and monitoring, performance evaluation, O&M planning, social accountability/grievance redress; (iv) oversight of construction supervision and contract management, and supervision of safeguards implementation; (v) approval of payment certificates from ULBs for works contracts and authorizations for payment; (vi) management of ULB performance evaluation, and disbursement of the performance-based allocation to eligible ULBs, in consultation with the Association; (vii) review and approval of O&M Plan and O&M support to ULBs, and monitoring compliance with performance indicators, in consultation with the Association. The LGED MGSP Organogram is shown in Figure 1. 3. Under Component 3(a), LGED will also be responsible for technical assistance, and selecting and managing consultants for:(i) environmental and social assessments; (ii) preparatory work, including training and workshops; (iii) governance and capacity development in the 26 ULBs, and results monitoring; (iv) ULB performance evaluation; (v) development of a GIS-based Urban Property and Asset Management System; (vi) piloting improvements in municipal finance management; (vii) design supervision and management, and O&M planning in ULBs; (viii) incremental contract staff; (ix) oversight of municipal training program, including procurement of computer hardware and software for computerization in ULBs; and (x) vehicles, office equipment, information technology equipment, maintenance and engineering equipment for ULBs.
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Figure 1. Organogram of Local Government Engineering Department
Local Government Division (LGD) Municipal Performance Review
Committee (MPRC) Chair, Secretary
Chief Engineer, LGED
Project Management Unit (PMU) Headed by Project Director
Project Steering Committee (PSC) Chair, Secretary
Project Implementation Unit (PIU) at ULB level, Headed by Mayor
Infrastructure Improvement Section (IIS); Headed by Engineering Head
Governance and Performance Improvement Section (GPIS); Headed by CEO/Secretary
Technical Assistance PIU Level
Technical Assistance PMU Level
Central Municipal Support Unit (CMSU) Headed by Director
Regional MSUs (RMSUs) Headed by Deputy Directors Non-Project
ULBs
Additional Chief Engineer (Urban) Project Coordinator
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4. Municipal Support Unit (MSU). The MSU was created in the Urban Wing of LGED by consolidating capacity-development programs supported by various projects, e.g., such as UGIIP-2 and the World Bank-funded MSP. In close coordination with LGD, PMU and LGED Training unit, MSU will be responsible for all capacity building activities in all ULBs and focused intensive training and other mentoring support activities for the 26 ULBs receiving project support, in addition to its capacity building program for all ULBs. Specific activities of MSU will include: (i) conducting training programs for ULBs in governance, financial management, and O&M planning; (ii) computerization program in ULBs through provision and training in computer-based management activities including computer hardware; and (iii) developing and managing the National Municipal Performance Monitoring System (on behalf of LGD), and producing action reports for decision-making by LGD.
5. Project Implementation Unit (PIU) at ULBs. A PIU will be established in each of the 26 ULBs to improve local municipal performance in line with the performance-based allocation requirements and to implement physical works supported by MGSP funding under Component 1. The PIU will be headed by the ULB Mayor who will be assisted by an Chief Executive Officer (CEO), Secretary, Head of the Engineering in project implementation, an infrastructure and services improvement unit headed by Head of the Engineering Unit and an urban governance improvement section headed by the CEO/Secretary. The PIU is expected to be the core unit for sustainable capacity improvement of ULBs after the project conclusion. Each PIU will prepare the Five Year Capital Investment Plan, including sub-project plans, and ensure that sufficient number of sub-projects have been prepared for implementation in the first year of the project.
6. Bangladesh Municipal Development Fund (BMDF) will be responsible for the overall management and implementation of Component 2 and parts of Component 3. BMDF will screen, review and appraise sub-project proposals prepared by ULBs, and provide financing to ULBs for sub-projects that meet appraisal requirements. BMDF will implement Component 2 with existing staff, supplemented by contract staff and consultants. The Managing Director of BMDF will function as the Project Director. See Figure 2 for the BMDF Organogram.
7. BMDF capacity building will include: (i) A Consultants team to develop a strategic road map for future sustainable operations for BMDF as well as operation support and capacity building to BMDF (ii) individual consultants (engineering, financial and safeguards) to assist in sub-project appraisals as well as develop standard templates of Sub-project proposals and appraisals for BMDF; (iii) incremental contract staff, including a procurement specialist and a financial management specialist; (iv) a consultant to develop a management information system; (v) training for ULBs and BMDF officials; (vi) workshops for municipal mayors and officials; (vii) office equipment and a vehicle; and (viii) incremental costs.
8. BMDF will engage, monitor and manage a Management and Supervision consultants team to reviewing and improving preparatory documents submitted by the ULBs to BMDF for funding and sub-project implementation management including procurement, construction supervision, quality & quantity control, and compliance with environmental and Social safeguard requirements etc.
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Figure 2. Organogram of Bangladesh Municipal Development Fund
MIS cum Monitoring Officer
General Body
Managing Director
Board of Directors
− Program manager − Urban development
Specialist − Procurement Specialist − Engineer Infrastructure − Junior Engineer cum
Record officer (2) − Auto Cad operator
Engineering Section
− Company secretary − Administrative officer − Public relation officer − Assistant Administrative Officer − Office assistant (General &
store) − Computer operator
Administration section
− Finance Manager
− Financial Analyst cum Controller
− Budget Control & Audit Officer
− Credit and Finance Officer
− Accounts officer
− ULB Capacity Building Coordinator
− Accountant
Finance & Accounts Section
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Financial Management, Disbursements and Procurement
Local Government Engineering Department (LGED) 9. Financial management and disbursement functions of the LGED part of the project will be undertaken by the financial management section in the PMU, supported by a Financial Management Specialist (FMS), reporting to the Project Director. The FMS will be a professional accountant capable of: (a) managing FM and disbursement functions to support implementation of project activities at the PMU; (b) assessing FM capacities of the ULBs and eligibility for project funding; and (c) assessing the requirements of funds for infrastructure activities under approved sub-projects of the ULBs, and disbursement. The FMS will be assisted by an Accounts Officer and two Accountants to be appointed from the existing LGD staff, preferably with experience in Bank-financed projects. The FMS and all other FM staff will be identified for recruitment as soon as possible but not later than February 28, 2014.
10. Fund Flow and Disbursement. The applicable disbursement methods would be Advance and Reimbursement. A segregated Designated Account (DA) will be established in a nationalized bank acceptable to the IDA, in the form of Convertible Taka Special Account (CONTASA), and managed by LGED. IDA funds may be advanced into the DA on the basis of six months’ forecast of project fund requirements to be included as part of the Interim Unaudited Financial Reports (IUFRs) that will be submitted by LGED to the Association within 45 days from the end of each quarter. MGSP funds to ULBs, including base allocations and performance-based allocations, will not be passed directly to ULBs. Funds required to execute the contracts under approved sub-projects of each ULB will be directly disbursed to the ULB’s contractors’ bank accounts through electronic bank transfer from LGED’s Designated Account on the basis of contractors invoices certified by ULBs, and approved by the Project Director. The advances deposited into the DA will be documented based on the actual paid expenditures reported by quarterly IUFRs.
11. The O&M allocation of US$20 million of IDA funds will be allocated to the 26 ULBs over the project period, as financial support for O&M improvement. Allocations will be reduced each year with a specified increase in ULBs’ contribution to O&M. LGED will transfer the O&M allocations to ULBs’ dedicated bank accounts as advance. At the end of each quarter, the ULBs will report utilization of the O&M financial support to LGED, which will then submit the application to IDA for documentation of advance as O&M expenditures.
12. Accounting and Reporting. LGED will record all financial transactions for the PMU and for the ULBs infrastructure and O&M in its project books of account and will submit quarterly IUFRs within 45 days from the end of each quarter. A format for IUFRs has been agreed between the Association and LGED, and has included a breakdown of project expenditures by disbursement categories, components and ULBs.
13. Computerized Accounting System. LGED had developed a Unified Financial Management System (UFMS), which is being tested for suitability for the project. In case the UFMS is not found appropriate for the project, an internationally reputed off-the-shelf accounting software will be procured and used from the start of the project.
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14. Audits. The LGED part of the project will be audited by the Foreign Aided Project Audit Directorate of the Comptroller and Auditor General, and the audited financial statements will be submitted to the Association within six months from the end of each financial year.
Bangladesh Municipal Development Fund (BMDF) 15. BMDF’s financial management section, headed by a Finance Manager, performed FM functions for the BMDF part of MSP and has been assessed to be adequate to undertake the financial management functions of the BMDF part of MGSP. BMDF currently has six FM staff in place out of seven approved staff positions, and it will fill the one vacant position before credit effectiveness. It will also enhance its capacity by engaging a Financial Management Expert to provide FM support to implement the BMDF part (Component 2) of the project and to provide on-the-job training to FM staff. BMDF’s FM activities will include assessing the financial management capabilities of the ULBs and eligibility for project funding, reviewing ULBs’ request for funds, and supervision and monitoring of ULBs’ utilization of project funds.
16. Fund Flow and Disbursement. Applicable disbursement methods would be Advance and Reimbursement. A segregated Designated Account (DA) will be established in a commercial bank acceptable to IDA in the form of Convertible Taka Special Account (CONTASA) and managed by BMDF. IDA funds may be advanced into the DA based on quarterly Interim Unaudited Financial Reports (IUFRs) that will include fund forecast for two quarters for: (i) approved sub-projects in the form of sub-credits to ULBs funded by the BMDF; and (ii) incremental operating costs. Every quarter, fund requirements for the next two quarters will be updated and additional funds required (over the balance of funds in the Designated Account) will be advanced to BMDF. ULBs will receive funds from BMDF upon meeting various payment milestones, as agreed with BMDF. Funds will flow from BMDF to ULBs on fulfillment of different installment criteria based on contractors’ invoices approved by the ULBs and verified by BMDF. Funds to ULBs from BMDF will be channelized to a dedicated Escrow Account of each ULB. The advances deposited into the DA will be documented based on the actual paid expenditures reported by quarterly IUFRs.
17. BMDF will draw project funds under a Subsidiary Loan and Grant Agreement (SLGA) between the Banking and Financial Institutions Division of Ministry of Finance (MoF) and BMDF. The SLGA will allow BMDF to retain the loans repaid by ULBs as seed money to continue municipal lending operations. The seed money will be part of BMDF’s capital funds as GoB contribution. Such capital funding will be recognized in the audited accounts of BMDF.
18. Accounting and Reporting. BMDF will record all project financial transactions for capacity building and loans and grants provided to the ULBs in its project books of account and will submit quarterly IUFRs within 45 days from the end of each quarter. The format of IUFRs will be agreed between the Association and BMDF, and will include a breakdown of project expenditures by disbursement categories, components and ULBs. BMDF’s entity computerized accounting system will be adequate to undertake project accounting functions.
19. Audits. The project component to be implemented by BMDF will be audited by a private audit firm that will audit BMDF’s entity financial statements and such audit under a TOR will include financial governance of major ULBs by rotation., Audit reports for each year will be submitted to the Association no later than six months from the end of each fiscal year. BMDF’s
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entity audited financial statements will also be submitted to the Bank each year within six months from the end of each financial year.
20. Operational Audit. Both LGED and BMDF will undertake operational audits on an annual basis by outsourcing the function to a reputed firm of chartered accountants under a TOR to be agreed with the Association. This audit will examine the physical, financial and operational aspects of project implementation and will provide timely feedback to project management and the Association with regard to strengthening the control framework and project management practices and evaluation of project performance.
21. Implementation of Audit Findings. A Deputy Project Director in the LGED PMU will be designated responsibility to ensure coordination and resolution of audit issues with relevant agencies and the Association. BMDF will designate this officer with appropriate seniority as the Task Officer on audit issues.
22. Supervision Plan. The overall FM risk of the project is assessed as “Substantial”, and Bank supervision will be conducted at least every six months.
Disbursement 23. Disbursement under the proposed credit will be made as indicated in the table below.
Category Amount of the Financing Allocated (expressed in
US$)
Percentage of Expenditures to be Financed
(inclusive of Taxes)
1. Goods, works, and services under Part 1(a) of the Project
184,000,000 90%
2. Goods, works, and services under Part 1(b) of the Project
20,000,000 71%
3. Goods, works, and services under Part 2 of the Project
155,000,000 90%
4. Goods, services, training and incremental operating costs under Part 3(a) of the Project
42,240,000 100%
5.Goods, services, training and incremental operating costs under Part 3(b) of the Project
7,760,000 100%
6.Goods, services, training and incremental operating costs under Part 3(c) under
1,000,000 100%
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the Project
7. Emergency Expenditures 100%
TOTAL CREDIT 410,000,000
Procurement 24. Procurement for the proposed project will be carried out in accordance with the World Bank’s "Guidelines: Procurement under IBRD Loans and IDA Credits" dated January 2011 (Procurement Guidelines); and "Guidelines: Selection and Employment of Consultants by World Bank Borrowers" dated January 2011 (Consultant Guidelines); and the provisions stipulated in the Financing Agreement.
25. All anticipated major procurement of works and consultants’ services have been announced in the General Procurement Notice (GPN), published in the Bank external website and in the United Nations Development Business (UNDB).
26. Procurement Responsibility. The overall responsibility of procurement implementation will be with LGED and BMDF.
27. Procurement of Goods and Works. Except as otherwise agreed in the procurement plan, works and goods may be procured on the basis of International Competitive Bidding. Procurement of Goods and Works having estimated value of less than the ceiling stipulated in the Procurement Plan may follow National Competitive Bidding (NCB) and Shopping. Direct Contracting (Goods/Works) and Single Source Selection (Consultants) may be allowed under special circumstances with the prior approval of the Bank. NCB will be carried out under Bank Procurement Guidelines following procedures for Open Tendering Method (OTM) of the People’s Republic of Bangladesh (Public Procurement Act 2006 - PPA, 1st amendment to PPA (2009) and The Public Procurement Rules 2008, as amended in August 2009) using standard bidding documents satisfactory to the Bank. The “Request for Quotation” document based on PPA is acceptable to IDA for shopping.
28. Procurement of non-consulting services. Except as otherwise agreed in the procurement plan, non-consulting services may be procured on the basis of International Competitive Bidding. Procurement of non-consulting services having estimated value less than the ceiling stipulated in the Procurement Plan may follow National Competitive Bidding (NCB). The agencies will carry out such procurement using Bank Guidelines.
29. Methods of Procurement of Consultants’ Services. The following methods will apply for selection of consultants: Quality- and Cost-Based Selection (QCBS), Quality-based selection (QBS), Fixed Budget Selection (FBS), Consultants’ Qualification (CQ), Least-Cost Selection (LCS), and Single-Source Selection (SSS). Shortlist of consultants for services estimated to cost less than US$300,000 equivalent per contract may be composed entirely of national consultants.
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The Procurement Plan will specify the circumstances and threshold under which specific methods will be applicable.
30. Incremental Operating Costs. These costs mean the reasonable costs of goods and non-consulting services required for the day-to-day coordination, administration and supervision of Project activities, including leasing and/or routine repair and maintenance of vehicles, equipment, facilities and office premises, fuel, office supplies, utilities, consumables, communication expenses, translation, printing, photocopying and postal expenses, bank charges, advertising expenses, insurance, costs of clearing, forwarding, inspection, survey and transportation of goods, Project-related meeting expenses, Project-related travel, subsistence and lodging expenses, salaries and allowances of LGED Project Management Unit contractual staff and BMDF staff assigned to the Project as agreed with the Association, and other administrative costs directly related to the Project.
31. Assessment of the Agency’s Capacity to Implement Procurement. A procurement capacity assessment of LGED and BMDF was conducted. As most of the works contracts are at the decentralized level (i.e., with different ULBs), both LGED and BMDF will require adequate procurement support through consulting firms to manage procurement under this project. Though significant procurement capacity development has been achieved in both for LGED and BMDF under MSP, the ULBs still have weaknesses in bid evaluation and contract management. In addition to adequate staffing for procurement needs, emphasis also needs to be placed on internal control, documentation, information dissemination, administration of contracts including delivery follow-up, payments, handling complaints, etc. Procurement risk for the project is rated “Substantial”.
32. In order to minimize procurement risks, the following measures have been agreed with the Government:
i. Identify procurement focal points (PFP) in LGED and BMDF. LGED and BMDF will nominate a procurement focal point for this Project. The appointed focal point will receive necessary training on PPR 2008 and on Bank Procurement Guidelines. The focal persons will help the respective agencies in day-to-day procurement follow-up and preparation of periodic procurement reports.
ii. e-Government Procurement (e-GP).The Bangladesh Central Procurement Technical Unit (CPTU) has introduced a web-based central e-GP system, which is used by four target agencies, including LGED. Both LGED and BMDF will introduce of e-tendering for works contracts in a phased approach. Both LGED and BMDF will identify ULBs which have adequate resources to initiate e-tendering. These ULBs and related bidders will be trained through the Public Procurement Reform Project II (PPRP II) and under MGSP.
iii. Procurement Training. Both LGED and BMDF will prepare procurement training plans for the project. The following training will be considered:
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Training type Organizer Costing
One / two day procurement orientation training for procurement staff of ULBs
BMDF and LGED Proposed MGSP
21 days procurement training for key procurement staff of ULBs
Engineering Staff College Bangladesh (ESCB)
PPRP II
Five days customized training for contract management for relevant ULB staff.
ESCB Proposed MGSP
iv. Thorough review and supervision by the Bank. Major contracts would be reviewed by the
Bank thoroughly; and, in addition, the Bank will appoint a qualified individual consultant to review contracts at various stages of evaluation, award, contract variations, and field visit to review implementation.
v. One member of the design, supervision and management consultant will be a mandatory member in each bid evaluation committee for all works contract.
vi. BMDF will hire a qualified procurement consultant for the project on a full time basis. This procurement consultant will be a member of each bid evaluation committee for goods and service contracts managed by BMDF.
vii. Establish a functional webpage for LGED / BMDF with procurement related information
accessible to the public. All information pertaining to bidding and procurement above the specified thresholds, as per PPR, will be published in Central Procurement Technical Unit’s (CPTU’s) website. LGED / BMDF will also publish procurement information on their websites.
viii. Establish a system for handling complaints and a database for recording, monitoring and follow up on project procurement activities under LGED / BMDF.
ix. Introduction of a Procurement Risk Mitigation Plan (PRMP) by LGED / BMDF through
reports submitted to IDA on a periodic (semi-annual) basis with a set of features as mentioned below.
33. Procurement Plan. A procurement plan for first 18 months of the project has been agreed with the Bank. It will also be available in the Project’s database and in IDA’s external website for the project. The Procurement Plan will be updated in agreement with LGED / BMDF, at least annually, to reflect the project implementation needs and adjustments thereof.
34. IDA Review of Procurement Decisions. IDA reviews of procurement decisions and selection of consultants will be governed by Appendix 1 of the Bank’s Guidelines. For each contract to be financed by credit, the threshold for prior review requirements and post review contracts are identified in the Procurement Plan. During the first 18 months of the project, IDA
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will carry out a prior review of the following contracts (this prior review threshold will be updated annually based on the performance of LGED / BMDF):
i. Goods. All ICB Contracts and Direct Contracts, irrespective of estimated cost, and NCB Contracts estimated to cost equivalent to or more than US$ 1,000,000.
ii. Works. All ICB contracts and Direct Contracts, irrespective of estimated cost, and NCB
Contracts estimated to cost equivalent or more than US$ 10,000,000. All 1st packages from new ULBs and ULBs with probable procurement risk.
iii. Non-consulting services. Contracts estimated cost equivalent or more than US$ 1,000,000. iv. Consultant Services. Prior review will be required for consultant services contracts
estimated to cost US$500,000 equivalent or more for firms, and US$200,000 equivalent or more for individuals. All single-source contracts will be subject to prior review by and in agreement with IDA. Terms of References for consultant services will be subject to prior review by the Bank.
Environmental Safeguards 35. Applicable Environmental Category and Safeguard Polices. The project is classified as a Category B project since no significant and/or irreversible adverse environmental issues are anticipated in the rehabilitation/new construction of basic urban infrastructure financed under the project. The policy on environment assessment (OP/BP 4.01) has been triggered for the proposed operation to ensure that project design and implementation will focus on reducing adverse impacts and enhancing positive impacts. The environmental safeguard policies, Natural Habitats (OP/BP 4.04) and Physical Cultural Resources (OP/BP 4.11) have been triggered as a precautionary measure.
36. Approach to Address Environmental Safeguard Issues. Details of sub-projects to be implemented under the project will be finalized during project implementation phase and therefore, the exact locations, size and extent of the sub-projects were not known at appraisal. In view of this, an Environmental Management Framework (EMF) has been prepared, describing the general baseline conditions and typical environmental impacts from different types of sub-projects during pre-construction, construction and operation.
37. The EMF provides guidelines to comply with national legislation and World Bank Group safeguards policies, and defines the environmental requirements needed for processing the financing of each sub-project. The EMF also describes the procedures for screening each sub-project for potential environmental impacts and to determine the scope of appropriate Environmental Impact Assessments (EIA).
38. The screening will help to determine whether a proposed sub-project needs an environmental assessment or whether it would be required to follow Environmental Codes of Practice (ECoP) to mitigate or avoid adverse impacts. ECoPs for different types of urban services at various stages (pre-construction, construction and operation) of project implementation have been provided in the EMF.
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39. The EMF identifies possible adverse environmental impacts and environmental considerations to be included in the design for reducing/eliminating adverse impacts. In general, sub-project impacts may include: drainage congestion, noise pollution, air pollution, water pollution, and environmental pollution from domestic and construction wastes. Sub-projects such as bridges, box culverts, and boat landing jetties may have minor ecological impacts that need to be assessed. The EMF provides detailed guidelines for such assessments.
40. The EMF requires sub-project specific Environmental Management Plans (EMP) to be prepared for all sub-projects having environmental impacts. The EMP will be an integral part of the Bill of Quantities (BOQ). ECoPs will be included in all sub-project civil works contracts through a set of special environmental clauses (SECs) in the Technical Specification of the bidding documents.
41. The EMF includes a provision for ‘Chance find’ procedures conforming to applicable legislations on heritage. n such cases, the executing agency will be responsible for the application of World Bank safeguard policy OP/BP 4.11: Physical Cultural Resources. The EMF also stipulates the code of practice on natural habitats as a precautionary measures.
42. In addition to the EMF, the relevant Environmental, Health and Safety Guidelines of the World Bank Group/International Finance Corporation (IFC) will be applicable to the project.
43. Capacity for Environmental Safeguards. LGED has developed institutional capacity for environmental management through implementing the IDA-funded Rural Transport Improvement Project (RTIP-I). An Environmental Unit headed by the Additional Chief Engineer (Maintenance) has been established in LGED. LGED is currently working on strengthening the Environmental Unit and also in training LGED officials and staff on environmental management.
44. BMDF is familiar with Bank procedures through its involvement in MSP. However, it does not have a dedicated unit for environmental management and will depend on consultant support. BMDF will develop its capacity for environmental management by providing training to its officials and staff with project support.
45. Environmental Safeguards Supervision and Monitoring. For Component 1, ULBs will be responsible for carrying out “environmental screening” and “analysis of alternatives” of each sub-project in accordance with the EMF. LGED will provide technical assistance to the ULBs in the preparation of all sub-project documents (including detail design, technical specification, cost estimation, and bid documents) and carrying out environmental screening and analysis of alternatives. Under Component 2, ULBs will engage consultant(s) for the preparation of sub-project documents during the first year, and will use standard templates supplied by BMDF to prepare their Sub-project proposals through consultant support hired by themselves in subsequent years.
46. Environmental screening and analysis of alternatives prepared by ULBs (in the prescribed formats provided in the EMF) will be reviewed by LGED/ BMDF, who will determine the need for additional environmental assessment (IEE/ EIA/ EMP) for these sub-projects. If additional environmental assessment is necessary, LGED/ BMDF will take necessary
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steps to carry out the assessment through a Consultant. LGED/ BMDF will be responsible for obtaining the necessary environmental clearances from the Department of Environment (DoE).
47. Environmental Monitoring. The LGED and BMDF will appoint consultants for independent monitoring of the overall environmental management of MGSP for LGED and BMDF. The ToR for environmental monitoring is included in the EMF.
48. Grievance Redress System. Environmental issues will be integrated into the project Suggestions and Complaints Mechanism (SCM) referred to in the Social Management Framework.
49. Consultation and Disclosure. The EMF was prepared in consultation with key stakeholders, including LGED and BMDF field level staff, contractors and communities. Consultation with communities is mandatory for environmental screening/assessment of each sub-project. The EMF, along with a Bangla version, has been disclosed by LGED and BMDF on their websites (www.lged.gov.bd, BMDF: www.bmdf-bd.org) and hardcopies have been made available at LGED and BMDF headquarters and at project ULBs. Advertisements requesting public comments have been published in two daily Newspapers (English and Bangla). The EMF has also been disclosed in Infoshop. Sub-project specific environmental screening/assessment will also be disclosed before the contractors mobilize.
Social Development and Safeguards
50. Social development concerns and safeguard compliance issues relate to proposed interventions for rehabilitation and new construction of basic urban infrastructure facilities such as roads; footpaths; storm water drainage; culverts; water supply systems; public toilets; car parks; street lights; pedestrian bridges; kitchen/municipal markets; bus/truck terminals; cattle market and office buildings. ULBs will ensure equitable benefits to all community groups, the very poor, tribal people, women and vulnerable groups and will try to carry out sub-project activities on existing sites or available lands. However, if additional land is required to accommodate civil works, land will be obtained through voluntary donation, direct purchase, or exchange. In cases where such methods are not feasible for critical amenities, involuntary land acquisition will be the last resort. The project has triggered Bank policies on Involuntary Resettlement (OP/BP 4.12) and on Indigenous Peoples (OP/BP 4.10). Land acquisition and resettlement/social development in sub-projects will be financed from GoB counterpart funding largely from ULBs’ own resources. A sum of US$9.25 million has been proposed for social development and safeguard management, which includes funds for land acquisition.
51. Planning approach. LGED has developed a Social Management Framework (SMF) –which is applicable to BMDF as well - to guide the planning and design of sub-projects on social development and safeguard compliance. Sub-project design will be carried out on an annual basis when sub-project activities are selected and designed. Social screening will be carried out as part of sub-project design and will include a social impact assessment, where social safeguard compliance issues are involved. Resettlement Action Plans (RAP) and/or a Tribal Peoples Plans (TrPP) will be prepared, where necessary. The RAPs/TrPPs will be reviewed and cleared by the Bank before the sub-projects are accepted for financing under the project. Social screening
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reports (SSR) of all sub-projects, and where necessary RAPs/TrPPs, will be disclosed in-country and in Bank Infoshop before bidding for sub-project implementation.
52. Social Management Framework (SMF). The SMF provides guidance on inclusion, participation, transparency and social accountability in sub-project identification, design and implementation. It includes: (a) a legal framework outlining the principles and guidelines to be used to acquire land and mitigate adverse impacts, including those on indigenous peoples; (b) a facility for screening of social development and safeguard issues related to involuntary resettlement, tribal peoples, and management of voluntary donations, direct purchase or exchange of lands; (c) mitigation principles and planning guidelines; (d) a grievance redress procedure for the beneficiary communities and affected persons; (e) a stakeholder consultation and participation framework; and (f) an arrangement for implementation as well as monitoring and evaluation of social development and safeguard measures. The SMF, along with Bangla summary, was disclosed in-country on LGED and BMDF websites on 22 September 2013.
53. Institutional arrangement and capacity building. BMDF and LGED have previous experience in implementing Bank financed infrastructure projects, where Bank guidelines on social safeguards, community participation and gender empowerment were applied. However, additional expertise in social development and safeguards compliance has been proposed for LGED, BMDF and the ULBs. The PMO in LGED will employ a full time senior Social Development Specialist and a full time junior Social Development Specialist. BMDF will employ a full time senior Social Development Specialist and two full time junior Social Development Specialists. In addition, a Social Development Officer (SDO) will be engaged at each ULB or existing staff will be assigned the responsibility of SDO for the sub-project period. The SDOs will be trained on social development and safeguard management as per the national legal system as well as on Bank policy on social issues and safeguards.
54. Social inclusion and gender mainstreaming. Sub-projects will be designed to ensure that vulnerable sections of communities including the very poor, women, tribal peoples, traditional minority communities, disabled and children, get access to benefits. Communities from each such group will be engaged in the project cycle from identification to design and implementation, and their opinions will be given due consideration. Sub-project information will be disclosed in the public domain, including the SMF and any subsequent RAPs and TrPPs. Specific measures will be designed for: (i) consultation, feedback and grievance-redress mechanisms to alert project staff to problems identified by beneficiaries, affected people, and other stakeholders; (ii) participatory planning to ensure the project meets the needs of beneficiaries; and (iii) participatory monitoring to identify problems. The project will promote Community Based Organizations (CBO), Ward Level Coordination Committees (WLCC) and Town Level Coordination Committees (TLCC) for formal involvement of the communities in the sub-project cycle at the ULB level. Beneficiary participation in selected ULBs will be mainstreamed through a disclosure and consultation process in the sub-project cycle.
55. Community Consultation. Extensive discussions will be carried out with communities during sub-project identification, planning and implementation. If a sub-project screening identifies tribal peoples among affected people/beneficiaries, ULBs will conduct free, prior and informed consultations with the tribal communities regarding their views on selection of the sub-project activity. LGED will prepare a Bangla translation of the SMF and an operational guideline for SMF implementation. Both LGED and BMDF will ensure that copies of the translated
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documents are available at their headquarters, at the selected and participating ULB offices and other local places accessible to the general public. The entitlement matrix for sub-projects will be made available to all affected persons in Bangla before the initiating bidding.
56. Grievance Response Mechanism. The project will establish a grievance response mechanism (GRM) to respond to queries, receive suggestions and address complaints and grievances about any irregularities in the application of the guidelines adopted in the SMF for inclusive project design, and assessment and mitigation of social and environmental impacts. This procedure will help to resolve issues/conflicts amicably and quickly, saving the aggrieved persons from having to resort to expensive, time-consuming legal action. However, this procedure does not pre-empt a person’s right to resort to the courts of law. Grievance response focal points will be available at ULBs and at the project level in LGED and in BMDF. A Grievance Redress Committee (GRC) will be formed in each ULB. The WLCC at the ward level will be the first focal point on project GRM. The GRC at the ULB level will be authorized to deal with suggestions and complaints at the sub-project level. Membership of the GRCs will ensure proper presentation of complaints and grievances as well as impartial hearings and investigations, and transparent resolutions. At least one member of the GRC will be a female, and will attend to grievances from female complainants. Where tribal peoples are among the beneficiaries or affected persons, the composition of the GRCs will take into account any traditional conflict resolution arrangements practiced by tribal communities.
57. ULBs will ensure that communities are fully informed about the GRM and their rights to offer suggestions and make complaints, and the different mechanisms through which they can do so, in particular grievances related to land acquisition and physical displacement.
Monitoring & Evaluation
58. Annex 1 provides the detailed Results Framework. Data to measure the project outcome and results will come from the annual performance assessments, an integral part of the design of Component 1, in addition to Household Survey data LGED and BMDF’s internal records.
59. Project Monitoring Arrangements. The LGED PMU will prepare quarterly progress reports, in accordance with the format outlined in the Project Implementation Manual. These reports will provide GoB and the World Bank with timely and updated information on implementation of project components, highlighting issues and problems. The progress reports will cover: (a) physical progress achieved against agreed implementation and disbursement indicators; (b) issues and problem areas, including comments on actions to address identified problems; and (c) work programs and cost estimates for the coming quarter, including revised estimates for the current quarter. BMDF will also submit quarterly progress reports which will include lending commitment levels, lending portfolio status, loan maturities, non-performing loans, etc. Performance and monitoring indicators will also be required from each ULB borrowing from BMDF.
60. The Project will be supervised jointly by World Bank staff and GoB at least three times during the first two years. Annual implementation reviews will be carried out to assess project progress, and a mid-term review will be carried out no later than June 2017. Within six months of the closing of the project, LGED and the BMDF will prepare an Implementation Completion Report (ICR) and submit it to GOB and the Bank.
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Annex 4: Operational Risk Assessment Framework (ORAF)
BANGLADESH: Municipal Governance and Services Project (P133653) Project Stakeholder Risks
Stakeholder Risk Rating Moderate
Description: Risk Management:
Municipalities which lag in reform and therefore receive fewer funds due to the performance-linked approach of MGSP, compared to traditional mechanisms for resource allocation may not be supportive of the project.
Continued dialog with relevant stakeholders, including municipalities and government agencies about the principles and long-term benefits of performance-based financial support. Ensure transparency of LGED procedures, project selection criteria, and annual performance assessments.
Resp: Stage: Recurrent: Due Date: Frequency: Status:
Bank and Client
Implementation Not Yet Due
Implementing Agency Risks (including fiduciary)
Capacity Rating Substantial
Description: Risk Management:
Weak implementation capacities and lack of contract management experience of urban local bodies, especially relating to Bank procurement and financial management requirements.
A comprehensive institutional capacity building, and technical and project management support has been included, along with benchmarking of municipalities on service provision, project management and construction supervision services, and capacity building for municipal government officials and technical staff. Bank missions will monitor the effective implementation of these measures and provide guidance and support as required.
Resp: Stage: Recurrent: Due Date: Frequency: Status:
Client and Bank
Implementation Not Yet Due
Governance Rating Substantial
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Description: Risk Management:
Governance arrangements for the project build on those of the predecessor project, MSP. However, the policies and procedure relating to the performance based allocation mechanism and the declining provision for O&M are new, in particular for ULBs. A large number of ULBs will be awarding sub-project contracts and managing implementation.
LGED and BMDF, together with their consultants, will provide guidance to the ULBs on working within the governance framework of the project. Bank implementation support missions will monitor the functioning of the governance arrangements and provide guidance on resolving issues. The project will make use of social accountability and transparency measures to improve project performance, including through third party monitoring, project level grievance redress mechanisms. LGED and the Bank will separately carry out independent external validations, which will include the annual performance assessments for the ULBs. Information officers will be appointed to respond to queries and requests for information from outside stakeholders. Procurement supervision will be enhanced with the presence of project management consultants, and close monitoring by Bank procurement staff. The GAAP will also be an important tool to monitor effective governance of the project by both GOB and the Bank.
Resp: Stage: Recurrent: Due Date: Frequency: Status:
Bank, LGED, and BMDF
Implementation Not Yet Due
Project Risks
Design Rating High
Description: Project design is complex: geographic scope potentially includes all ULBs in Bangladesh; funds provided through LGED and BMDF; adoption of a framework approach; innovations introduced through performance based allocations and declining O&M financial support (complemented by increased own contribution from ULBs for O&M). Extensive consultations have taken place during project preparation and
Risk Management:
LGED, BMDF, and their consultants will provide guidance and support to the ULBs in implementing the project as designed. The Bank will monitor the effectiveness of the arrangements to implement the project as designed through frequent missions (including visits to select ULBs), especially during the first year. The efficacy of the design will be reviewed during the mid-term review and adjustments will be made, as required.
Resp: Stage: Recurrent: Due Date: Frequency: Status:
Client and Bank
Implementation Not Yet Due
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project design has been explained to all stakeholders. Project components include consultant support to LGED, BMDF, and ULBs in sub-project preparation and implementation. Floods frequently plagued the country and could cause damage to infrastructure
Social and Environmental Rating Moderate
Description: Risk Management:
The project is anticipated to have positive social consequences for residents who will benefit from improved key infrastructure. Acceptable EMF and SMF have been prepared. Preparation of sub-project specific safeguard documents and their satisfactory implementation by a large number of ULBs could be a challenge.
LGED, BMDF and the consultants will provide guidance to the ULBs to prepare acceptable EIAs, EMPs, ECoPs, RAPs, and TrPPs for sub-projects, as appropriate and monitor their implementation. Independent validations, including performance assessments carried out for the ULBs, will also review the social and environmental aspects of the project. Bank missions will review and clear sub-project specific safeguard documents and monitor their implementation through site visits, discussions with ULBs/BMDF/LGED/consultants, and through review of periodic reports, including independent reports. The Bank will provide guidance in ensuring compliance with safeguard documents as necessary.
Resp: Stage: Recurrent: Due Date: Frequency: Status:
Client and Bank
Implementation Not Yet Due
Program and Donor Rating Moderate
Description: Risk Management:
WBI and other donors (e.g., Korea Research Institute for Human Settlements) plan to complement MGSP. The activities of these agencies will need to be coordinated to avoid mismatches in timing or objectives, as well as delayed implementation of complementary activities.
The Bank, together with LGED and BMDF, will maintain close and on-going cooperation with other donors during MGSP implementation to ensure early identification of possible misalignments and improve synergy between donor inputs.
Resp: Stage: Recurrent: Due Date: Frequency: Status:
LGED, BMDF, Bank
Implementation Not Yet Due
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Delivery Monitoring and Sustainability
Rating Substantial
Description: Risk Management:
Monitoring the quality, timeliness and cost of delivery of the different elements of this project by a large number of ULBs will require considerable effort. M&E arrangements and steps towards sustainability have been built into the project design.
LGED and BMDF, with help from their consultants will guide ULBs in achieving delivering project outputs (e,g.,.sub-projects, own source revenue enhancements, enhanced O&M contributions) in an effective manner. They will also ensure the implementation of the project M&E system and measures to strengthen sustainability. Bank implementation support missions will monitor all three aspects – delivery quality, M&E, and sustainability –on an on-going basis through site visits, review of reports, and periodic discussions with key decision makers in the sector in GOB.
Resp: Stage: Recurrent: Due Date: Frequency: Status:
LGED, BMDF, and Bank
Implementation Not Yet Due
Implementation Risk Rating: Substantial
Comments:
Project implementation risk is rated substantial because implementation agency risks related to weak governance, and inadequate capacity, and delivery monitoring & sustainability are substantial, and project design risk is rated high. Project design includes necessary measures, by both LGED and BMDF, to mitigate the above risks including: (i) provision of consultant services support to ULBs; (ii) oversight of contract award decisions; and (iii) and joint measurement of works and approval of payment certificates before payments are made to contractors. In addition, the Bank will provide intensive implementation support.
Nondisclosable Information for Management Attention (Optional) (Note for information: this section is not disclosed at Negotiation and Board presentation stages)
Comments:
The overall risk rating for the project is Substantial. This is based on governance risks primarily due to the operating environment and the multitude of contracts involved. These risks will be carefully assessed throughout the project's preparation and implementation phases through the use of the ORAF and the preparation of a GAAP.
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Annex 5: Implementation Support Plan
Strategy and Approach for Implementation Support
1. The strategy for implementation support has been developed based on the risk assessment through the ORAF process. It focuses on those risk categories rate substantial or high risk, i.e., capacity. Governance, design, and delivery monitoring & sustainability.
2. Stakeholder. All stakeholders, primarily ULBs, will be informed of the new performance-based financial support based on improvements in governance. LGED and BMDF will convey the message through workshops and consultations. The project will provide technical assistance to both agencies to address these risks. The Bank will provide additional support to propagate the new approach during supervision missions.
3. Capacity. The project includes comprehensive capacity building technical assistance for: (i) consultant services to ULBs for project preparation, implementation and management; (ii) consultant services support to LGED and BMDF to manage their respective components; (iii) consultant services for annual performance assessment of ULBs; and (iv) technical assistance to the LGD to develop a national performance monitoring system. Bank implementation support missions will monitor the effectiveness of these arrangements (especially fiduciary aspects) and provide appropriate guidance to resolve any issues.
4. Governance. The project will mitigate governance risks through a social accountability system to ensure transparency and inclusiveness, and improve project performance to mitigate governance risks through third party monitoring, and project level grievance redress mechanisms. These are captured in the GAAP, which will provide an additional tool to monitor actions to mitigate governance risks. The Bank will enhance oversight in the areas of procurement and financial management.
5. Design. Given the complexity of project design, including innovative features such as annual performance-based allocations and O&M financial support on a declining basis (complemented by increased O&M allocation by ULBs), the project includes substantial international and national consultant support to LGDE, BMDF, and ULBs to help implement the project. LGED and BMDF, with assistance from their consultants, will guide ULBs in the implementation of the project. Bank missions will work closely with LGED and BMDF to ensure that the design (especially the innovative features) are adhered to. Bank missions will work with LGED and BMDF in refinements to the design, as needed, based on implementation experience.
6. Social and Environmental. Social and environmental risks will be mitigated through the development of IEE/EIA/EMP and SMP/RAP (and if necessary RPF and TrPP), with support from experienced consultants. Bank social and environmental safeguard specialists will ensure that the required safeguard documents are specific, comprehensive yet practical, and are achievable. The Bank will ensure that sufficient training is provided on safeguards, and that adequate resources are allocated for monitoring the implementation of the EMPs/ECOPs/RAPs/TrPPs. The Bank will review LGED and independent monitoring reports on
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safeguards implementation and also carry out intensive site visits during implementation support missions for a first hand assessment of compliance with Bank safeguards requirements. It will follow-up with meetings at the appropriate level to resolve issues identified.
7. Delivery Monitoring and Sustainability. Bank missions will carefully monitor the timely release of funds to ULBs through LGED and BMDF, based on agreed appraisal procedures for sub-projects. The Bank will pay special attention to the annual assessments of ULB performance and the provision of enhanced O&M funds by ULBs under Component 1. Implementation support missions will monitor sustainability through: (i) participating ULBs’ successful implementation of revenue enhancement plans and improved revenue collection; (ii) ULBs’ enhanced O&M budgeting and maintenance schedules; and (iii) improved debt recovery performance of BMDF.
8. The Project will be supervised jointly by World Bank staff and GoB at least twice a year during the first two years. Annual implementation reviews will be carried out jointly by GoB and the Bank. A Mid-Term Review will be carried out no later than June, 2017 to evaluate progress and make necessary adjustments.
Implementation Support Plan
Primary Focus of Implementation Support
Time Focus Skills Needed Resource Estimate First twelve months
TOR preparation (completed)
Selection of all consultants Disbursement of base
allocation Sub-project design
preparation Procurement Safeguards Preparation for
performance assessment
Technical (municipal engineering and O&M expertise)
Safeguards Financial
management Procurement
Bank Country office staff (safeguards, procurement, and financial management) engage with LGED and BMDF as needed, with formal reviews about two times. Washington-based team (TTL, engineer, public finance) visit the project twice.
12-24 months
Performance assessment Definition of performance
bonus Procurement Project implementation Monitoring and
supervision
Technical (engineering, planning, TTL, Co-TTL)
Safeguards Financial
management Procurement M&E
Full team supervision twice a year.
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24-60 months
Performance assessment Definition of performance
bonus Procurement Project implementation Monitoring and
supervision Mid-term review
Technical (engineering, planning, TTL, Co-TTL)
Safeguards Financial
management Procurement M&E
Full team supervision twice a year
60-66 months
GoB infusion of performance-based allocation
Seek GoB adoption of the performance-based allocation in own ADP
Draft ICR
Task team Leader/co-Task team leader, economist, public finance specialist
Final full team supervision
Other Skills Mix Required for Core Team Members
Skills Needed Number of Staff Weeks Number of Trips
Comments
Senior Urban Specialist (TTL)
1 staff member: 16 weeks
4 4 trips + 2 weeks per project year (shared with other projects in the country).
Senior Urban Specialist (co-TTL)
1 staff member: 16 weeks
In field office
Day to day implementation support
Senior Governance Specialist Component 1)
1 staff member: 8 weeks
2 2 trips + 2 weeks per project year
Economist/Financial Specialist (Component 2 BMDF operations)
1 staff member: 8 weeks 2 2 trips + 2 weeks per project year
Civil Engineer 1 staff member/consultant: 8 weeks
2 2 trip + 2 weeks per project year
M&E Specialist 1 staff member/consultant: 8 weeks
2 2 trip + 2 weeks per project year
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Annex 6. Governance and Accountability Action Plan (GAAP)
1. The Bank's Country Assistance Strategy (FYI1-14) for Bangladesh defined weak governance as a binding constraint to inclusive growth and committed the Bank to embedding more systematic approaches to governance challenges across the portfolio. Urban governance is weak and lacks effective citizen participation, accountability, or financial management. Citizens, in particular the poor and women, do not have effective avenues to influence decision making. 2. The Governance and Accountability Action Plan (GAAP) for MGSP outlines a framework for actions, institutional arrangements, and additional specific measures to minimize governance and corruption risks in the project. It incorporates lessons from MSP in the assessment of the critical governance and corruption risks and in designing the action plan for mitigating the risks. 3. Governance and corruption risks in the proposed project fall into four major categories: (i) service delivery risk; (ii) capacity risk; (iii) procurement risk; and (iv) financial management risk. MGSP design is based on, inter alia, an analysis of these risks and includes appropriate risk management measures, as described in Annex 2: Detailed Project Description, and Annex 3: Implementation Arrangements. The GAAP Matrix in the attachment to this Annex focuses on: financial management and procurement; and ULB level activities. The latter addresses: fiduciary systems capacity building; enhanced transparency and accountability; service delivery strengthening; and capacity training to implement sub-projects. 4. The GAAP will be monitored regularly through indicators and reflected in progress reports, as well as during Bank implementation support mission. It will be adjusted as necessary during implementation to reflect governance issues which may emerge and/or to add actions.
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Governance and Accountability Action Plan (GAAP) Matrix of Actions
Area of work Issues likely to affect project performance
Actions to address the issues Responsible agency
Timeline
Financial management and procurement
Sub-optimal procurement practices and outcomes at ULBs. “Leakages” in cash-based operations.
Agreed procurement risk mitigation action plan that is monitored on a regular basis, including procurement performance monitoring indicators.
Carrying out robust procurement
(including technical) audits of project FM and procurement beginning, four months into project implementation.
LGED on supervision of procurement
and contract management in schemes implemented in 26 ULBs..
BMDF supervision and monitoring of
ULBs supported by it. Bank supervision of fiduciary aspects, including through field visits to ULBs.
Review of contract implementation by
independent consultant/third party monitoring. The supervision consultant team will include a member of bid evaluation committee.
Use of fraud and corruption checklist of red flags in tender evaluation.
Procurement will be done using EGP in a phased in manner on the basis of the capacity assessment of ULBs.
Adequate disclosure of procurement plan and invitation for tenders.
LGED/ BMDF
Ongoing
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ULB level Activities
Fiduciary systems capacity building
Weak ULB capacities on procurement and financial management
Independent assessments of ULBS receiving funds from LGED/BMDF.
Capacity building training for financial management and procurement staff at the 26 selected ULBs as well as BMDF supported ULBs.
Computerized accounting system installed and being used; computer-generated accounting reports to be produced for ULB/city councils and made public.
ULBs/ LGED/ BMDF
Annual
Enhanced Transparency and Accountability
Weak mechanisms for downward accountability
TLCC & WLCC functioning effectively.
GRC receives and addresses
complaints/grievances and provides annual reports on complaints received and actions taken.
Set up sign boards with contract
information and Grievance Redress Mechanism contact information at each participating ULBs to enable beneficiaries to monitor progress of works.
Public Budget Hearing announced in local media at least 30 days in advance. Pourashava budget proposal discussed in TLCC.
Annual External Audit report presented
to the Mayor &the Council and made public.
An Independent firm recruited to
conduct Third Party Monitoring.
ULBs/ LGED/ BMDF/ LGD
Annual/Ongoing
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Service delivery strengthening
Sub-optimal service delivery affecting ULB/ Project
Annual O&M plan prepared with necessary budgetary resources allocated.
Service Delivery Improvement Action
Plan (SIAP) developed / implemented by municipal department with community involvement (in line with Citizen Charter and O&M Plan / Budget).
ULBs/ LGED
Annual
Capacity Training to implement sub-projects
Weak ULB capacity to implement sub-projects
Targeted capacity building programs for the pre-selected 26 ULBs and BMDF supported ULBs on municipal governance and performance.
Support for horizontal learning opportunities across municipalities and broader capacity building efforts for all ULBs in the country.
MSU/ LGED/ BMDF
Annual
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