INTEGRATED RURAL SANITATION in UPPER EGYPT LUXOR – IRSUE-LUXOR (Result Based Finance Programme- RBF)

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AFRICAN DEVELOPMENT BANK GROUP

INTEGRATED RURAL SANITATION IN UPPER EGYPT LUXOR – IRSUE-LUXOR (Result Based Finance Programme- RBF)

SUMMARY OF THE STARTEGIC ENVIRONMENTAL AND SOCIAL ASSESSMENT (SESA)

EGYPT

May 2019

1. Introduction 1.1 Rational for Bank Engagement and Choice of the RBF Instrument In August 2018, the Minister of Housing, Utilities, and Urban Communities (MHUUC), responsible for water supply and sanitation services, requested the Bank’s support to the National Rural Sanitation Program (NRSP), highlighting the Government’s willingness to advance institutional measures needed for the successful implementation of the program. The overall focus of the Bank’s rural sanitation intervention in Egypt is to improve access and services in different Governorates in Upper Egypt, which discharge untreated wastewater into the drain system. This first phase of the Bank financed program will be geographically localized in Luxor Governorate. The Bank's engagement in the sector using this new results-based financing instrument is justified for three reasons: (i) the existence of a nation-wide program with clear and quantifiable objectives; (ii) the existence of a long-term budgetary expenditure framework; and (iii) the conclusive results of the technical, environmental and fiduciary assessments. 1.2 Climate, environmental and Social (CES) categorization As per the Bank’s RBF Policy, the following criteria and activities were excluded from the project during the preliminary assessment: (i) any activity that requires the preparation of Full Resettlement Action Plan (RAP) and any other high risk/impact activity classified as Category 1 under the Bank’s Integrated Safeguards System (ISS); and (ii) high-value individual contracts (US$50M for works, turnkey & supply & installation contracts, US$30M for goods; US$20M for ICT systems and non-consulting services, US$15M for consulting services).

Thus, the physical infrastructures of the IRSUE-Luxor does not include any Category-1-type activities. In line with the Bank’s Environmental and Social Assessment Procedures (ESAP), the overall environmental and social risk of the Bank’s program was assessed as medium, which trigger the category 2 according to the Bank’s Integrated Safeguards System (ISS) and the category B based on the national environment protection is Law 4/1994, amended by Law 9/2009 and law 5/2015 and its Executive Regulations and decrees including the 75/2017 one. In reference to the climate risks, the preliminary data on the Bank’s program indicate that the planned infrastructure (water sanitation plants, stations, etc.) are not located in areas vulnerable to climate change. The category 3 was assigned based on the Bank’s climate screening system tool (CSS).

2. Program description 2.1 Program Objectives The National Rural Sanitation Program (NRSP), in which the Bank’s programs embedded, aims to provide universal access to rural sanitation services and to reinforce a series of performance improvement measures at the local utility level. It is supported by national initiatives to address persistent sector challenges such as low cost recovery. The NRSP sets out to strengthen decision-making at the local level by increasing the financial viability and operational and managerial performance, as well as the capacity of the local utilities, and improving the overall accountability framework. The Integrated Rural Sanitation in Upper Egypt program will be focusing on the NRSP Program Results Area I, II and III in Luxor and at national level, which aim at improving the sanitation access in the Governorates of Luxor and the operational stability and functionality of the Luxor Water and Sanitation Companies (WSCs). The IRSUE-Luxor program aims at designing integrated sanitation systems of "clusters" by collecting and treating wastewater generated from some rural areas in Upper Egypt, thereby contributing to clean environment by increasing the coverage of improved sanitation for the populations living in these areas. The Bank’s Program focuses on one Water and Sanitation Company (WSC) operating in the Governorate of Luxor.

2.2 Program results areas and geographic scope The project is articulated around three areas of intervention, closely intertwined, as follows: • Results Area 1: Increasing access to integrated and improved sanitation system: The activities under this component will involve collecting, transporting, treating and disposal of wastewater from household level to discharge level. • GoE vision for the sector put special emphasis in the access to basic infrastructure for the poorest. The Bank’s, through the RWSSI Fund, will contribute to establish a pilot mechanism to facilitate access to sanitation sewerage to (5-7)% of the total households (about 1500 households). • Results area 2: Building capacities for improved operational system and practices of Luxor WSCs (LWSC). The activities under this result area aims to strengthen the capacities and improving existing mechanisms to increase the IRSUE-Luxor sustainability and maximize its impacts. It involves a series of activities interconnected that enhance the technical, environmental, financial and social sustainability of the intervention. A capacity development plan will be designed and implemented, benefitting LWSC staff, including women. • Results area 3: Strengthening National Sector institutional Framework. A technical assistance program is considered to help the PMU, which will be also strengthened with Bank’s program-dedicated staff, to overcome identified gaps in planning, procurement, program management, engineering and E&S. Feasibility studies, supported in part by RWSSI TF, will be conducted to draft the second phase of the Bank’s program targeting additional rural population in the Governorate. The proposed RBF operation “IRSUE-Luxor” is geographically localized in Luxor Governorate within the wider national program in Upper Egypt located 635 km south of Cairo, along the Nile Valley and its desert fringe in Upper Egypt. It covers an area of about 416 km², which consists of five administrative localities (Districts and major cities): Luxor, Teba, Aramant, Esna and El Karna. The IRSUE-Luxor’s cost is UA 85.84 million ADB Loan and Euro 1 million RWSSI Grant - equivalent to US$ 121.14 million. The table below summarizes the major expected results and specify the geographic scope of the IRSUE-Luxor. Table 1 - Results Area and geographic scope EXPECTED RESULTS GEOGRAPHIC SCOPE

Results Area 1: Increased access to integrated and improved sanitation system

At least 25,000 HH with new access to an improved working Rural areas in Luxor Governorate sanitation service in the area of intervention, of which at least 10% of which 11 villages and its HH are in satellite villages related satellites.

About 1,500 poor households connected to the sewerage system Rural areas in Luxor Governorate

60% of Luxor rural population connected to improved sanitation Rural areas in Luxor Governorate systems 02 WWTP designed and constructed Rural areas in Luxor Governorate

Results Area 2: Capacity built for improved operational system and practices of Luxor WSC

Capacity building plan (benefiting at least 30% of women) Rural areas in Luxor Governorate implemented

100% of procurement under the project follow established Luxor Governorate procurement procedures as per revised and approved PPM

Annual Performance-based Capital Transfer (PBCT) from Luxor Governorate MHUUC1 to LWSC

Standard set of Environmental and social clauses for construction Luxor Governorate activities developed LWSC Citizen engagement & Corporate Social Responsibility Luxor Governorate platform established and active Gender informed public and environmental health awareness 11 villages in the Luxor programs to strengthen community engagement conducted Governorate

Results Area 3: Strengthened National Sector Institutional Framework

PIU operational and provided with appropriate staff LWSC

Approval of the Procurement Procedures Manual (PPM) by the LWSC Luxor WSC’s Board. sludge management plan for Luxor governorate LWSC

Improved enabling environment for more sustainable rural LWSC sanitation services 2.3 Infrastructure components of the IRSUE-Luxor and beneficiaries The physical components under the IRSUE-Luxor will target Luxor Governorate and specifically the District of Esna and El-Tood, integrating a total of 11 mother villages and its related satellites. The IRSUE-Luxor, will develop 11 sewer networks (various sizes - 200 to 900 mm) and pump stations, force mains, crossings, 2 small scale wastewater treatment plants located in the desert areas of El Tod and El Keman El Matana respectively. The network will serve approximately 25,0002 households. The households in satellite villages that are not be covered by the sewer network will be served by a fleet of desludging trucks. The 2 Wastewater Treatment Plants will be treating wastewater from respectively two different clusters named respectively Al-Tod/El-Dabayba and Keman El Matana: • The Al-Tod/El Dbayba Cluster’s (for Esna East and El-Tod districts) wastewater will be treated in the Wastewater Treatment Plan WWTP located in Al-Tod covering the following 6 main villages comprising their satellites: Alshaghab, Elmalla, El Dabayba, Altoot Gharb, Alodysat Quebly, Alodysat Bahry. The Plant will be designed for a capacity of about 13,000 m3 per day for 135,431 people in 2040 (and 80,634 in 2019). • The Keman El Matana WWTP will be designed for 152,057 people in 2040 (90,532 in 2019), or for the treatment of about 22,000 m3 per day from 5 main villages that are Keman, Asfoun, Alghryrah, Tafneis and, Halfa 3, with their respective satellites.

1 Ministry of Housing, Utilities, and Urban Communities 2 Based on the exiting water supply connection 3

The sludge from these settings will be then unloaded to the wastewater treatment plants. The sewage sludge treatment and disposal will use thickening facilities and drying beds for sludge dewatering. Giving the scale of the WWTP, the quantity of sludge produced will not be important. The direct beneficiaries of the program include 171,000 persons in 2019 but the population in these areas should expand to 288,000 by 2040. It is worth noting that the infrastructure has been designed to meet the 2040 demographic estimates. The program will also benefit to 30,000 indirect beneficiaries (i.e. farmers impacted by sanitation). This intervention in Luxor Governorate will increase sanitation of coverage from current 3% to 60% in the rural areas of the Governorate of Luxor. Table 2 - Main villages and Population in the Area of intervention Cluster N° VIllages Population 2019 1 Keman 33 156 2 Asfoun 22 512 Keman Cluster 3 Alghryrah 8 889 4 Tafneis 18 829 5 Halfa 3 7 146 1 Alshaghab 14 819 2 Elmalla 11 510 3 El Dabayba 5 316 El Dbayba Cluster 4 Altood Gharb 15 255 5 Alodysat Qebly 19 194 6 Alodysat Bahry 14 540 Total 171 166

3. Climate, Environmental and Social (CES) Assessment 3.1 Environmental and social main positive impacts With regard to the environmental sustainability, the IRSUE-Luxor is expected to enhance the sustainability of watercourses by improving their quality, the sustainability of agriculture lands by alleviating the rising groundwater table problems, and improving the quality of irrigation water. In addition to that, the main environmental and social benefits in the IRSUE-Luxor are:

• Diminishing the current problems related to sewage especially health problems • Improving groundwater quality in most of the Bank’s program areas through the prevention of sewage leaking into groundwater. • Creating job opportunities for Labours and technicians. • Provision of sewage service to a wide sector of the population • Decreasing the odors and spread of insects significantly in the zone of intervention.

Also, the Bank’s program has several positive impacts on women and marginalized groups:

• The sanitation system will save women effort of carrying water and getting rid of it in the sewage trenches or on the streets. • The improved health conditions especially among children will relief social burdens imposed upon women in this sense as they take care of sick children and elderly groups.

• Provision of sewage services will benefit mostly the poorest groups who suffer from financial burdens related to sewage trenches discharging. Poorest groups will also feel that the government is keen to improve their access to services. • Childers will benefit from the Bank’s program as they can take showers more often without worry of sewage trenches fullness.

3.2 Environmental and social risks and adverse impacts The overall identified risks related to the IRSUE-Luxor are as follow:

• Risk of social tensions as a result of the exclusion of certain villages especially small ones (Ezba or Naga): For multiple technical and financial reasons, certain villages might be left behind without benefiting from the project. The risk emerges if the excluded villages are located near other villages that will be receiving the service. This risk will be mitigated by determining the satellite selection criteria. • Risk of damages during the construction activities: The operations of digging machinery in narrow streets of villages may cause some damages to the houses and other structures. In the cases where the measures are not explicitly indicated in the contract and in cases of weaknesses in the supervisory role over the contactor, the potential risk from such cases may escalate for this Risk assessment and management reports and the ESMP must be prepared before construction • Risks of pollution during the operation phase of the sub-projects due to discharging of noncomplying effluent, sewerage blockage or leakage that should be considered in the EIA and the ESMP

Although the overall environmental risks are moderate, some individual risks related to the subprojects are rated substantial in the absence of mitigation measures. The main environmental risks are those related to improper handling of sludge (Moderate); risks of improper handling of solid wastes separated at the WWTPS and PSs (Moderate); risks of discharging noncomplying effluent (Major); risks of sewerage blockage or leakage during operation (Moderate); and risks of improper handling of chance-find culturally valuable objects (Minor).

On the impacts side, no sensitive habitats were identified within the Bank’s program areas, neither culturally valuable sites and no unprecedented impacts are identified or expected under the IRSUE-LUXOR. The planned physical infrastructure will result in low to moderate impacts including:

• Land acquisition: The physical infrastructure included in the IRSUE-LUXOR entails limited land acquisition for constructing the two WWTP affecting land use areas of respectively 105 and 158 ha in the desert, as well as additional lands for constructing the Pumping stations (less than 1ha per station). While the WWTPs lands are state owned areas, most of the PSs lands in the project are still in the process to be as state owned areas. At this stage, the LWSC staff is working closely with the community members to finalize the land acquisition process of the pumping stations. While land acquisition laws and procedures as well as the consultation procedures and grievance redress mechanism are well established under the NRSP, securing the Pumping stations (PSs) lands may face some challenges due to the limited experience of the LWSC staff in conducting and monitoring the land acquisition activities. The SOP should be applied Common construction-related impact: such as deterioration of air quality during transportation of material and installation of the facilities; soil pollution, noise and vibration, general occupational health and safety impacts to workers and the affected communities, production of drilling mud and cleaning water, in addition to the solid wastes generation; • Impacts associated to the poor management of the temporary impacts related to setting up construction camps and other potential activities that likely result in temporary disturbance to the use of land (for example, occupying land temporarily) or damage to land-based assets (for example, damaging crops).

• Impacts associated to the operational phase such as pollution due to leakage and misuse of equipment and material at the treatment plant The IRSUE-Luxor is likely to have detrimental site-specific environmental and social impacts that can be minimized by applying appropriate management and mitigation measures or incorporating internationally recognized design criteria and standards. No cumulative impacts are to be noted at this stage of the proposed program, however, in case waste stabilisation pond technology is the method adopted for the WWTP, this will result in an increasing of the algae concentration in the effluent and cause surface water pollution. Assessment of the country legal, regulatory, and institutional framework for environmental and social management systems

Between 2015 and 2017, Water and Sanitation Program -funding was invested in laying the groundwork required to reform institutions before implementation could take off. Activities focused on the development of country systems in three selected priority areas (citizen engagement, procurement and Monitoring and Evaluation (M&E)), were agreed between the WB (under the NSRP Program -SRPSS) and the GoE and achieved a number of significant results including the following:

• Update of standard operating procedures for land acquisition (Land SOP), • Establishment of a Ministerial decree an inter-Ministerial Committee in charge of citizen engagement related activities to engage citizens and strengthen direct beneficiary feedback; • Development of a project related Grievance Redress Mechanism (GRM) guidelines and community engagement guidelines; which contributed to embedding participatory planning and improve GRM’s functioning. After assessing the current system and identifying the gaps In compliance with the Bank’s RBF guidelines, IRSUE-Luxor will rely on the country system for its implementation, which will ensure sustainability and, at the same time, will work on the improvement of the national and monitoring and evaluation procedures and systems.

The IRSUE-Luxor will be therefore implemented using existing national system and structures currently being utilized under NSRP at Ministry Level (MHUUC-PMU) to ensure continuity and benefit from the results of the NSRP (SRPSS).

The existing legislations, policies, and guidelines, overall adequately address the overall environmental and social issues associated with the program. This include the environmental risks assessment; the effluent and water quality standards limits, sludge and septage handling procedures, sewerage networks management, hazardous substances and solid waste management requirements , air quality and noise standards and limits, archeological and cultural heritage and wastewater reuse specifications especially for irrigation purposes.

However, the assessment conducted identified a number of gaps linked to the compliance with the national standards and limits and the local procedures of the HCWW/WSC, which does not sufficiently include compliance mechanisms. The limited institutional capacity of theses institutions was found as one of the main challenge in the existing procedures, in fact, the WSCs have limited institutional capacity in addition to the limited experience in managing the Environmental and social issues as many of the required environmental and social measures are usually carried out by the National Organization for Potable Water and Sanitary Drainage (NOPWASD). In addition, some issues such as sludge handling and health, safety, and environment issues require specific expertise that in not readily available at the WSCs level. With regards to the Environmental and social management system in place, the following management gaps are to be noted:

• Handling of Sludge: The handling of sludge generated at the WWTPs is regulated through the Egyptian code of practice of 501 for year 2015. According to the law, if the dried sludge is to be used as organic fertilizer, it should meet certain standards; otherwise, it should be landfilled or safely incinerated. These standards are generally equivalent to international sludge standards. However, with regard to application, the WSCs do not monitor the sludge quality as required by Egyptian Law before selling it as fertilizer for agricultural lands. The most common scenario for sewage sludge treatment and disposal in most of the existing WWTPs in Egypt is using thickening facilities and drying beds for sludge dewatering. The dried sludge is mainly used for land application or it is rarely dumped into landfill. It is noted that, this scenario of sewage sludge treatment does not contain facilities for sludge stabilization processes. Moreover, the quality of the produced sludge in most of the WWTPs doesn’t fit with the international standards, especially pathogens limits. • Handling of Septage: The discharge of septage removed from individual septic tanks and cesspits are regulated by Law 48/1982, however, in practice septage are removed in unserved areas by local contractors using tankers (discharge the septage in the nearest location in an agriculture drain or even in freshwater canals). The lack of an official system to handle septage can have detrimental effects on surface water quality. Accordingly, on-site sanitation including an official septage management system that would serve remote and satellite villages has been considered in the IRSUE-Luxor. 4 Consultations Consultations with local communities and village-level stakeholders were conducted through focus group discussions and public meetings. To ensure convenience to the local communities and allow for participation from women, village-level consultations took place in the villages reaching out to the targeted unserved communities: In the communities’ Hosting halls, non-Governmental organization, and Local Governorate Units (LGUs). In addition, meetings and small workshops with the relevant departments in the targeted governorate were organized and included the Public Awareness and Customer Service Department, The Citizens’ Service and Hotline Department, Sanitation Sector; Quality Sector; and Occupational Health and Safety Department.. According to the dissemination plan The main outputs of the consultation process are related to the shortfalls in the existing systems and its impacts on health and expenditure of the local population, the willingness of the villages to contribute to new sanitation projects, which include a contribution with land. Besides, the appraisal mission of the project identified the clear willingness from the private sector to support the overall objective of the Integrated Rural Sanitation project in Luxor. This includes financial and non-financial support (in kind contribution / training) to poor households. 5 Operational safeguard matrix and Recommended Actions to Address Identified Risks and Gaps Using the Integrated Safeguards system (ISS) as benchmarks, a diagnostic assessment of applicable and relevant national, program and/or sector level laws, regulations, rules, and procedures for managing and mitigating the CES impacts of the IRSUE-Luxor was carried out and an action plan proposed for adoption. The following table presents the operational safeguard matrix and the proposed action to mitigate the IRSUE-Luxor risks:

5.1 Operational safeguard matrix Operational Actions already taken or included in the design of the Objectives Requirements applicable to the IRSUE-LUXOR Gaps Proposed Action Safeguard (OS) IRSP

• Assign environmental, social and health and • To identify and assess the safety specialists (with minimum 5 years • EIA study for Dbabiya cluster need to be experience) on a full-time basis at the PIU environmental and social impacts - EIA study has been Conducted for Keman El prepared and submitted to EEAA. level. The EHS specialists shall be supported (including gender) and climate change Matana and approval from EEAA 3. • Screening and exclusion for potential category 1 • PIU shall be established by an environmental specialist and social vulnerability issues projects from the scope of IRSUE-Luxor (Based for the project under the specialist at the PMU level or at PMCF. - Monitoring and follow up procedure during on the Bank’s E&S policy) IRSUE-Luxor with • To avoid or if not possible minimize, • Application of Environmental law 4/year 1994. environmental and social construction phase and operation phase are mitigate and compensate for adverse • Consultation with communities before and during mandates. • The PMU and PIU should ensure maintaining OS 1 designated in the approved EIA. and after the construction. • Community engagement of the boundaries of IRSUE-Luxor to the listed Environmental impacts on the environment and on • Disclosure of the environmental and social management is suffering identified clusters on ensure that no DLIs and social affected communities; - Environmental and Social Safeguards Assessment studies. from limited resources under IRSUE-Luxor are linked with any and the proposed action plan have been conducted. assessment • To ensure that affected communities • Meeting with the contractors and the ISC after (lack of staff; lack of potential category 1 project planned under the awarding of each contract to discuss the resources for overall NRSP. have timely access to information in Dissemination plan should be prepared including safeguards and their application. publications and • The PMU shall ensure that the PIU: suitable forms about Bank operations number of meetings such as (pre-construction • Assign an environment supervisor to ensure transportation; - Monitor and follow up IRSUE-Luxor and are consulted meaningfully about meeting - during-construction meeting – after - implementation of ESMP during civil works. monitoring system; implementation issues that may affect them construction meeting) • Assign Safeguards experts (environmental and limitation in mandates; - Designate an environment supervisor to social) for training the safeguards officers etc.) ensure implementation of ESMP during

(environmental and social). civil works. - Strengthen Community engagement management • IRSUE-Luxor land acquisition for constructing •To avoid involuntary resettlement the PSs and the WWTPs lands are in the approval where feasible, or minimize process. The Ministry of Housing, Utilities and The lack of the inter- resettlement impacts where involuntary Urban Communities, through the National agencies’ coordination role Program for Sanitation in Rural Areas, has resettlement is unavoidable, exploring to facilitate the process of established a set of standardized standard obtaining approvals may OS 2 all viable Bank’s program designs; procedures for land acquisition to mitigate and result in a delay in the Assign an engineer from LWSC for following up control the intensity of these impacts: • Application of the Project Level Involuntary • To ensure that displaced people Grievance Mechanism established process of finalizing land and speed up the procedure of land acquisitions. resettlement • Level Grievance Mechanism is established and receive significant resettlement under the SRSSP acquisition (steps # 5 & 6) This engineer needs to have fully authorization land acquisition, approved under the SRSSP. One of the key assistance so that their standards of formal grievance channels is the Hotline and the • Implementation of the land acquisition from the LWSC for facilitating his mission until population living, and overall means of livelihood one which is meant, by design, to be the single standard procedure he obtain the various approvals of all the required displacement are improved beyond pre-Bank’s official channel. The HCWW is working to lands. and strengthen the Hotline system—including the call program levels; compensation centers within the WSCs—and is aiming, through • To set up a mechanism for this strengthening, to enable this channel to be the monitoring the performance of single official uptake modality • From site visits and official documents, it is clear involuntary resettlement programs in that IRSUE-Luxor will not result in resettlement Bank operations and remedying activities since the land acquisition for problems as they arise so as to constructing the PSs and the WWTPs lands in the zone of intervention are already now in the step #

3 Egyptian Environmental Affairs agency 8

safeguard against ill-prepared and 5 (Obtain various approvals) in the 6 steps that poorly implemented resettlement plans are normally taken for voluntary land donation.

All selected areas for PSs and WWTP are in places • To preserve and restore biological that will not affect the biological diversity. diversity by avoiding, or if not possible, No gaps are identified reducing and minimizing impacts on PSs are in the areas selected to avoid any detrimental

biodiversity; impact on the nearby householders. Also, WWTPs OS 3 • To protect natural, modified and have been selected in the desert area far from the Biodiversity and residential areas by more than 500 m and they are critical habitats; and to sustain the ecosystem availability and productivity of priority selected in areas that have no animal settlement and services ecosystem services to maintain benefits plants cultivation. to the affected communities and to In case the treatment plant is away from the nearest sustain project performance. residential area less than 500 meters, a health impact assessment report is required in accordance with the decision of the Minister of Health

- Potential Incompliance of treated wastewater from the two WWTPs with law 48 for year 1982 for the disposal into • Develop a mitigation plan to reduce the algae - Treated wastewater disposal in a drain and sludge agricultural drains due to concentration in the effluent linked to the use • To manage and reduce pollutants used for land applications and irrigation should be potential high algae the technology of waste stabilization likely to be caused by IRSUE-Luxor so carried out in manner consistent with the Egyptian concentration in the • Carrying out a study for sustainable sludge that they shall not pose harmful risks to -Hazardous and Non-Hazardous waste generation is law 48 for year 1982 and the Egyptian code of effluent of the waste management and reuse / disposal plan for OS 4 Pollution stabilization ponds. human health and the environment, fully controlled by implementing the mitigation and practice of 501 for year 2015 and the World Health IRSUE-Luxor including: prevention and including hazardous, non hazardous monitoring measures in the approved EIA study. . - Currently practice of 1. Identify the end-use market for sludge reuse : control, Organization (WHO) Guidelines for the Safe Use of reusing the sludge waste and GHG emissions. Wastewater, Excreta and Grey water and applicable - Sludge composting to produce organic hazardous -The storage and disposal of hazardous wastes have without sludge biological national requirements. treatment in agricultural fertilizers suitable for reuse in agriculture materials and • To set a framework for efficiently carefully performed as to abide by the existing legal resource lands may has its - Production of electricity or gas for cooking utilizing all IRSUE-Luxor raw framework and the periodical monitoring from the - Law 4/1994 on Environmental Protection provides influences on the efficiency from the biogas produced from the materials and natural resources ministry of Environment. detailed information on the law limit on Hazardous environment and health anaerobic digestion units. especially focusing on energy and aspects. and non-hazardous waste - Use of dry sludge in the operation of Bad management and water. - cement kilns. control on the disposal of 2. Carry out study for Septage management in septage at the un sewered Luxor governorate villages is also may have its impact on the health aspects.

OS 5 labour Standard Bidding Documents (SBDs) (volume 2) labours health and safety Develop a set of standards for Labour protection • To protect the workers’ rights Application of the workers’ rights, protection conditions, have been issued under NRSP with new aspects to and their insurance are conditions clauses based on Egyptian and • To promote compliance with against workforce inequality, other social exclusion, health and assure the application of Egyptian Labour law and to assured in SBDs. However, internationally recognized standards specific for national legal requirements and and child Labour and forced Labour protection. safety provide due diligence in case cover the Labours and community as follows: workers’ rights; protection the construction activities

national laws are silent or against workforce inconsistent with the OS; inequality; other social • To provide broad consistency with 1- Sub-contractor Labors insurance exclusion; and child labour 2- OHSE mitigation measures the relevant International Labor and forced labour need to Organization (ILO) Conventions, 3- Community HSE be secured in the ILO Core Labor Standards and the 4- ESMP UNICEF Convention on the Rights 5- Daily financial penalty in case of the documents. of the Child in cases where national absence of the HSE procedures laws do not provide equivalent This can be done by protection; applying Egyptian Labour • To protect the workforce from Law No. 12 for 2003 for inequality, social exclusion, child the protection, occupational Labor and forced Labor; and health and safety for the • To establish requirements to provide workers, which is safe and healthy working conditions amending Law 137 for Year 1981 and its executive decrees and the international construction standards requirements needs.

5.2 Additional measures to enhance the community and citizen engagement The conducted institutional assessment for handling community engagement showed that while specific community engagement guidelines exist, the current mechanism is still suffering from the limited resources. Therefore, IRSUE-Luxor included the following additional measures to strengthen the PMU, reinforce the capacity of LWSC and enhance sustainability: • Creation of Corporate Social Responsibility (CSR) platform for water and sanitation in Luxor governorate in order to coordinate and streamline their actions and align their approaches. • Design gender and social outreach program for LWSC • Provide logistic support to public relation and customers care departments • Training of different governorates in Upper Egypt on Procurement Construction Management, Citizen Engagement, M&E, The costs of these measures are included in the following table:

Table 3 - Agreed Actions linked to citizen engagement under RWSSI Trust Fund

Proposed Action Cost in Euro Explanation

STRENGTHENING THE NATIONAL PMU AND LWSC

Creation of CSR platform for 10,000 This includes financial and non-financial support (in kind water and sanitation in Luxor contribution / training) to poor households. The private sector needs governorate a platform (Corporate Social Responsibility) to be developed in order to coordinate and streamline their approach and contribution

CAPACITY DEVELOPMENT FOR ENHANCING SUSTAINABILITY

Package consulting contract to 150,000 The value addition of the project would be to promote social and design gender and social gender inclusion and increasing economic opportunity. (i) There is a outreach program for LWSC. need to increase the participation of community especially women. To enhance community participation especially women LWSC need to be equipped (policy and technically) to undertake effective outreach program. (ii) Unemployment is very high among the youth. Skills training of youth will create employment opportunities during the consultation and operation of the project is proposed. (iii) Due to cultural issues, women need to be equipped with the basic plumbing and quick fix solutions. A training and equipment for basic services will be provided to women. (iv) Gender informed education and communication material and programme for hygiene and health will address the current hygiene problems. Moreover, Training of LWSC staff in communication, environmental and social safeguards, gender and social inclusion, public participation, and monitoring and reporting. This will be designed in a way to involve LWSC staff and achieve “learning by doing”.

Logistics Support 50,000 The public relation and customers care departments need to be strengthened in terms of equipment and mobility. Small equipment such as printers and computers for LWSC network in governorate. There is a need as well for multi-proposal vehicle.

IMPROVING THE GOVERNANCE AND GRIEVANCES SYSTEM

Training of differents 30,000 governorates on upper Egypt on Procurement Construction Management, Citizen Engagement, M&E and Land SOP

6 E&S institutional arrangement and capacity building The institutional arrangement set up under the SRSSP include a PMU at the MHUUC funded by WB, and the exiting PIU, at LWSC funded by USAID. The current arrangement is as follow:

• A Sector Coordination Inter-ministerial Steering Committee, with major stakeholders (the Holding Company for Water and Wastewater, Ministry of Health, Ministry of Water Resources and Irrigation, Ministry of Environment, Ministry of International Cooperation, and Ministry of Finance) provides an overall guidance on the Program. • The Program Management Unit (PMU) of The Ministry of Housing, Utilities, and Urban Communities (MHUUC), established in 2015 are representing the Executive Agency , oversight and coordinating functions as well as strategic and policy guidance to the SRPP.

In terms of institutional complexity, the environmental and social issues will be handled through different bodies (PMU, PIU, PMCF, etc.) and the system is expected to operate without complexity. That said, a dedicated Program Implementation Unit (PIU) at LWSC will be established for the daily – daily implementation and management of IRSUE-Luxor.

Under the Technical Engineering Consultant, the following staff will be recruited: Water and Sanitation Engineer, Procurement Specialist, Financial Management specialist, Environmental and social specialist, Health and safety specialist, and Contract Management and Legal Specialist.

To enable the assigned E&S teams in the LWSCs to carry out their responsibilities as planned, a training on safeguards and environmental health and safety protection has been included in the RBF action plan for the safeguard teams in the implementing agencies. With the colLabouration of the existing safeguard team at the PMU level and with the assistant of PMCF, environmental and social specialists along with health and safety specialist will be recruited and trained to strengthen the technical capacity of the implementing agency (PIU) in Luxor to: i) ensure the maintain of the IRSUE-Luxor boundaries to the listed identified clusters and the exclusion of any category 1 project that could be linked to the achievement of the IRSUE-Luxor DLIs; ii) monitor and follow-up on the construction activities and iii) to strengthen Community engagement management. In addition, an engineer from LWSC will be assigned to follow up and speed up the procedure of land acquisitions established under the SRSSP at the PMU level.

With regard to the completion measurement responsibility, the The GoE will hire an internationally reputed firm with a strong local presence to be the Independent Verification agency (IVA) under the IRSUE-Luxor. The firm selected will demonstrate a wide array of competencies, and will have an international reputation to live up to. The IVA will work with EWRA, the Egyptian Water Regulatory Agency as feasible, since EWRA will be able to provide substantial information and analysis as required.

Table 4 – Technical and CES capacity building program

Action Description Date Due Responsible Completion Party Measurement

Technical

1. LWSC trained on network 2022 - 2023 PMCF 4, IVA5 Report cleaning technics HCWW, PMU

2. LWSC trained on O&M of the 2023-2024 PMCF, Luxor IVA Report newly built WWTPs WSC

3. Awareness campaigns 2020 - 2025 PMCF, Luxor IVA Report implemented for a better use of WSC the HH connections by the people served

Climate, Environmental and Social

3.1 WWTPs: Operational Health Before construction phase PMCF and Measuring the return of and Safety PMU the training course by evaluating sheets 3.2 Construction Sites: Before construction phase PMCF and Operational Health and Safety PMU

3.3 Community: Occupational Before construction phase PMCF and health and safety PMU

3.4 ESIA for sanitation Project Before construction phase PMCF and PMU

3.5 Environmental aspects in Before construction phase PMCF and Wastewater treatment and PMU Effluent quality regulations

3.6 Decentralized wastewater In the first year of construction PMCF and treatment options / on site phase PMU sanitation

3.7 Environmental registers in In the first year of construction PMCF and WWTPs phase PMU

3.8 Sludge management and reuse After the approval of the strategic PMCF and master plan for sustainable sludge PMU management and reuse / disposal plan

7 Procedures for Grievances Redress One of the key formal grievance channels is the Hotline and the one, which is meant, by design, to be the single official channel. The HCWW is working to strengthen the Hotline system—including the call centers within the WSCs—and is aiming, through this strengthening, to enable this channel to be the single official uptake modality.

4 Program Management Consultant Firm (PMCF) 5 Independent Verification Agency (IVA) 13

However, in practice, In Luxor -similar to other governorates- most complaints are still being communicated through other informal channels including verbally to Labouratory staff, maintenance service staff, security, commercial personnel, or the media

Through the SRSSP program, project-level Grievances Redress Manual (GRM) has been approved and adopted by the Ministry of Housing. This GRM can be applied and followed during the construction and operation phases. In addition, the project will finance 20.000 Euros to undertake the assessment of the existing complain mechanism in order to ensure that the community services is also included by the Complaints Management System. 8 Monitoring & Evaluation The NSRP developed a Monitoring and Evaluation (M&E) system during its first phase of implementation, in 2015. IRSUE-Luxor will use and strengthen the system in place, and adapt it to the context of LWSC and reinforcing its capacities.

The project M&E system is based on the Results Framework with monitoring at all levels, including activities, outputs and outcomes. DLIs, as part of the indicators, will be monitored following the M&E system established. The M&E will be done at five levels of detail and frequency: • Normal day-to-day program management monitoring carried out by Implementation Support Consultant (ISC) on the infrastructure implementation, and the normal day-to-day monitoring systems used by the LWSCs for their service; • A Quarterly Financial Reports prepared by the PMU and ISCs with collaboration with the LWC and following the Bank’s rules. • A bi-annual Program Reports, prepared by the PMU and ISCs on behalf of the LWC and following the Bank’s rules. Bi-annual reports will be done in close collaboration with ISC and LWC, which will provide data. Reports will also detail the activities and results during the 6 months, including implementation progress, fiduciary status, stakeholder participation, safeguards risks and mitigation measures as well as highlighting issues and decisions needed; • Annual validation assessment by the IVA to audit the DLI achievements. Evidence of the DLI achievements will be present by the PMU to the IVA, which is tasked with verifying the results. In order to validate the disbursement request submitted by the PMU, the IVA will verify all DLI target indicators through a desk review and physical inspection. IVA report must be validated by the Bank prior to disbursement. • A Mid-term review by the Bank after two years. The CES monitoring plan included in the project’s overall monitoring plan is presented in the below table: Table 5 : Climate Environmental ,Social monitoring plan

DLI Responsible Completion Action Description Date Due (Yes/No) party Measurement

Climate, Environmental and Social

Recruit environmental, social Within one month Hiring specialists in the and health and safety No after IRSUE-Luxor LWSC company specialists launching

Ensure that no DLIs under the IRSUE-Luxor are linked At design period No potential category 1 PMU and with any potential category 1 No and before project planned under PIU project planned under the construction phase the overall NRSP overall NRSP

No environmental or E&S monitoring and follow During construction PMU and social problems / No up construction phase phase PIU accidents during the construction

Designate an environment supervisor to ensure During construction PMU and Hiring environment No implementation of ESMP phase PIU supervisor during construction

Strengthen Community PMCF, PMU Well designed mandate No During all phases engagement management and PIU is set

Assign 2 engineers for following up and speed up At design period the procedure of land Land acquisition No and before LWSC acquisitions in cooperation procedures are finished construction phase with the legal and property departments

Develop a master plan for Strategic master plan for sustainable sludge During design and PMCF, PMU sustainable sludge No management and reuse / construction period and LWSC management is disposal plan developed

Develop a Septage During design and PMCF, PMU Septage Management No Management System construction period and LWSC System is developed

Developing a mitigation plan Before the end of PMCF, PMU Effluent requirements to reduce the algae No construction phase and LWSC are maintained concentration in the effluent

Develop a set of standards Environmental, health and safety, and labour conditions Environmental, health During design and PMCF and clauses based on No and safety, and labour tendering period PMU internationally recognized conditions are met standards specific for the construction activities

Hiring of consultancy Adoption and implementation During the life span firm to package the of the Citizen Engagement NO LWSC of the project capacity building and Framework on-job training.

Hiring of consultancy Gender and social inclusion During the project No LWSC firm to package the awareness raising cycle capacity building and on-job training.

Gender and Social Inclusion Policy for Inclusive Technical Expert for infrastructure (pro-poor No PMU Pro-Poor policy for households connections)

After Pro-Poor 5% poor households policy approved PMU and Identification of the connections of which 14% of No and households PIU poor households female headed households connection started

capacity building and on-job training by the Training of women on Before and after Awareness department plumbing and small repairs of No LWSC construction phase public relations and breakdowns community participation departments

At start-up of the Hiring of consultancy Gender Sensitive Health and construction and firm to package the No LWSC Hygiene Promotion during capacity building and implementation on-job training.

The Annual Performance Assessment (APA), which was established between the local and the national level to assess the performance of the WSC included among the 12 Key Performance Indicators (KPIs) specific KPIs linked to citizen engagement. The LWSC, with the assistance of the PMU, will design and approve a Performance Improvement Action Plan, which will be evaluated through the APA.

Table 6 - LWSC KPIs linked to citizen engagement Name Unit Definition

PERFORMANCE AREA 4- CITIZEN ENGAGEMENT

Resolution of complaints within % Percentage of registered complaints that were resolved within 24 24 hours hours during a year; calculated by dividing the number of complaints resolved within 24 hours by the total number of complaints registered over that year in the complaint management system (CMS)..

Community services and Nr Number of complaints handling entities connected to the participation entities captured by Complaints Management System and fully operational with the Complaints Management trained staff and equipment. A sustained entity is one available System that are established and continuously during government working hours and comprising a sustained building or room, an operational computer connected to the CMS, and a trained operator.

Name Unit Definition

Quarterly community engagement Nr The number of qualifying Quarterly reports in one calendar year reports verified by spot checks on period documenting application of the community engagement resolved complaints. process as defined in the Procedural Guidelines.

A qualifying quarterly period is one where 85% of spot checks on a sample of monthly resolved complaints during that quarter are correctly recorded. The spot checks shall be evenly distributed across all sanitation related categories which are as follows (1) Flooding, (2) Settlement, (3) Broken pipe, (4) Stolen of manhole cover, (5) Other. A minimum of 30 spot checks shall be made per quarter spread evenly over the three months covered. The spot checks shall be made only in villages covered by the Program. Percentages shall be rounded up to the next whole number.