AFB/PPRC.24-25/5 ADAPTATION FUND BOARD SECRETARIAT TECHNICAL REVIEW OF PROJECT/PROGRAMME PROPOSAL PROJECT/PROGRAMME CATEGORY: Full Proposal Country/Region: Iran, Islamic Republic of Project Title: Reducing vulnerability to climate change in the Lake Bakhtegan Basin Thematic Focal Area: Water Management Implementing Entity: United Nations Development Programme (UNDP) AF Project ID: IRN/MIE/Water/2018/1 IE Project ID: Requested Financing from Adaptation Fund (US Dollars): 9,865,651 Reviewer and contact person: Mr. Hugo Remaury Co-reviewer(s): Mr. Dirk Lamberts IE Contact Person: Ms. Lianchawii Chhakchhuak Review Criteria Questions Comments 1st May 2019 Comments 15th May 2019 UNDP Response 1. Is the country Yes. party to the Kyoto Protocol? Country 2. Is the country a Yes. Eligibility developing country particularly vulnerable to the adverse effects of climate change? 1. Has the Yes. designated government authority for the Adaptation Fund endorsed the project/programme? Project Eligibility 2. Does the length of Yes CAR 6: Please ensure the proposal amount compliance with pages’ to no more than Fifty limitation set for fully- pages for the developed project project/programme document and their concept, including its annexes. AFB/PPRC.24-25/5 annexes; or One hundred pages for the fully-developed project document, and one hundred pages for its annexes? 3. Does the project / CR 1: Please explain how CR1: Addressed, as per programme support the project will ensure that information provided on concrete adaptation the alternative livelihoods page 29. actions to assist the activities that will be country in addressing identified in output 2.2 will adaptive capacity to generate sufficient economic the adverse effects of returns (e.g. using estimated climate change and Net Present Value or build in climate Internal/Economic Rate of resilience? Return) to ensure the sustainability of the activities supported beyond the project lifetime. CR2: Some activities described CR2: Addressed, as per under output 3.1 (para 135) are information provided on not mentioned or do not have page 82. corresponding targets, means of verification or risks/assumptions in the project results framework (section E of the proposal). Please include such information in the results framework and ensure coherence between the description of the activities and the information provided in the results framework. 4. Does the project / Likely. programme provide AFB/PPRC.24-25/5 economic, social and CR3: Please describe the CR3: Addressed, as per environmental process (and associated information provided on benefits, particularly selection criteria) through which page 27. to vulnerable the project will distribute benefits communities, from output 2.1 amongst including gender beneficiaries. considerations, while avoiding or mitigating negative impacts, in compliance with the Environmental and Social Policy and Gender Policy of the Fund? 5. Is the project / Yes. programme cost effective? 6. Is the project / Yes. programme consistent with national or sub- national sustainable development strategies, national or sub-national development plans, poverty reduction strategies, national communications and adaptation programs of action and other relevant instruments? 7. Does the project / Unclear. The section entitled programme meet the “D. Technical Viability” relevant national includes an overview of technical standards, relevant regulations and where applicable, in national technical standards, AFB/PPRC.24-25/5 compliance with the as well as a statement that Environmental and the project conforms with Social Policy of the these. However, apart from Fund? information on compliance with national EIA requirements, the proposal does not state what are the implications of these regulations and standard requirements for the project, nor how it will comply with them. CR4: Please clarify CR4: Not addressed. Please CR4: The ESMF contains a methodology for compliance of the project describe how the project compliance with AF Principles, the first of activities (those which activities meets relevant which is compliance with the law. This is have national standards (kindly further reinforced in the pre-screening been already identified) with refer to OPG Annex 5 for template which, even before formal USP all relevant technical further guidance on screening takes place, requires the standards listed in that compliance with this identification of all relevant national laws and section, notably in table 10. criterion). regulations, and a listing of any applications for permits, etc., that have been made. Regarding compliance Ongoing monitoring, and ongoing with national EIA stakeholder consultation (relevant authorities regulations, the are an important stakeholder), ensure requirements are unclear. continued compliance. For instance, the proposal includes apparently contradictory information, stating on one hand that “Any development project affecting more than 5000 ha in any part of the country or projects in protected areas requires EIA assessment and authorization by DoE prior AFB/PPRC.24-25/5 to implementation” – para 221 while on the other hand explaining that none of the proposed activities/outputs require Environmental Impact Assessments (paras 223 and 225), although the project is said to affect areas much larger than 5,000 ha. CR5: Please clarify the CR5: Not addressed. Please CR5: As per decision made by Environment requirements for the project clarify in an evidence-based High Council and Cabinet in June 2011, 53 to comply with national EIA and substantiated manner types of projects require EIA report and regulations, and in particular the requirements for the confirmation of the Department of the outcome of the screening project activities to comply Environment (DOE) for further process. with national EIA regulations implementation. These projects fall under 7 and describe the outcomes main categories, including 1) Rails, Roads The DoE is the executing of the EIA screening and Airports 2) Power plants 3) entity of the project while at process. Petrochemical, Refineries 4) oil and gas pipe the same time it is charged lines 4) Mine and industries 5) Large dams with enforcing compliance and water infrastructures 6) Large service with relevant national EIA providing projects 7) Agro-Industry Units. regulations. The proposed activities under the AF project do not fall under any of the above 7 CR6: Please clarify how categories and hence are not envisaged as this conflict of interest will requiring EIA. Nevertheless, screening of be addressed. USPs against AF Principles has not yet CR6: Addressed, as per taken place and cannot be pre-empted. CR7: Given the various USPs information provided on While at this stage it is not envisaged that (see CAR1 below), please page 50. any USP will require a full EIA/ESIA, as describe in the ESMP how the further screening of all USPs is to take place project will ensure compliance CR7: Not addressed. Given as part of project implementation, it cannot with all relevant national the various USPs, please be ruled out. Procedures for screening technical standards once the describe in the ESMP how against AF requirements, in a manner activities will be identified. the project will ensure commensurate with a project’s magnitude AFB/PPRC.24-25/5 compliance with all relevant and likely impacts, are detailed in the ESMF national technical standards in Annex 10. once the activities will be identified. The changes have been reflected in para 220. CR 5: The ESMF (Annex 10) contains procedures for assessing each project’s projected E&S impacts, and a means of managing them. This will be done to an extent that is commensurate with likely impacts. “Commensurate with likely impacts” covers a wide range of assessment, from a brief discussion with local stakeholders (for a very small scale one-off activity), to a full EIA where needed, although this is not currently foreseen. In the event that an EIA is required by law, this is covered by Principle 1: compliance with the law, which is the first part of screening for AF compliance. CR 7: Procedure for USPs included in the ESMF – Annex 10. 8. Is there No. duplication of project / programme with other funding sources? 9. Does the project / Yes. CR8: Based on previous experience of joint programme have a projects with line ministries and entities, the learning and CR8: Please clarify who will be CR8: Not addressed. Please concerned education and public relation knowledge the “Implementing Agency” to elaborate on the measures offices responsible for KM products and management whom the website and “that will be put in place to updating website will be involved in the component to capture associated social medias will be ensure sustainability and project activities from the initial stages. and feedback handed over at project closure. continuation of these Project KM products will be reflected both in lessons? platforms” at project end. project and ministry website and in training modules. The handing over process will be done gradually with the Department of AFB/PPRC.24-25/5 Environment (DoE). The project will have a specific section in the DoE website with agreed process for its maintenance. Based on best practices of other development projects, in the final year of project, a data bank of knowledge products will be developed and shared among all stakeholders and published in DoE and other related ministries’ website. This has been reflected in Para 241. 10. Has a consultative Yes. process taken place, and has it involved